Privacy Policy

JACOBIN FOUNDATION, LTD

Effective January 2022

Jacobin Foundation, LTD, a New York not-for-profit corporation, d/b/a Catalyst Journal (“Catalyst” in this Privacy Policy) respects your privacy as a visitor to its website and has developed the following privacy policy to inform you about how we handle your personal information after receiving it. This Privacy Policy governs Catalyst’s use of your information on our website catalyst-journal.com.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you can choose not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

California residents under 13 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.
Controller
Catalyst is the controller and responsible for your personal information (“Catalyst,” “we,” “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out in Section 18 below.

You have the right to make a complaint at any time to European Union supervisory authorities for data protection issues (https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en). We would, however, appreciate the chance to deal with your concerns before you approach such authorities so please contact us in the first instance.
Types of Information Collected and Stored
1. Personal Information Summary.
  When you engage in activities such as sign up to receive Catalyst journal or other publications, make donations to Catalyst, shop on our website, or otherwise use the Catalyst website, Catalyst may gather your personally identifiable information (“Personal Information”).
  
  Your Personal Information may generally include, but is not limited to, your name, address, phone number, email address, electronic signature, IP addresses, geo-location, or any other personally identifying data collected from you by Catalyst or its authorized agents.
  
  By using the Catalyst website, you agree to allow Catalyst and its agents to gather, store, and share your Personal Information subject to the limits of this Online Privacy Policy.
2. Specific types of data we collect about you. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  1. Identity Data includes first name, maiden name, last name, username or similar identifier.
  2. Contact Data includes billing address, delivery address, and email address.
  3. Financial Data. When you use the Catalyst website to purchase a subscription, to shop, or to make donations to Catalyst, Catalyst utilizes third-party payment processors as its agents (“Payment Agents”) to process your payment and provide payment verification to Catalyst concerning your payment. Catalyst and its Payment Agents utilize systems whereby we substitute a proxy set of identifying information for your real financial information. Our Payment Agents, which do handle your credit cards and other payment information, are PCI Data Security Standard (“PCI DSS”) compliant. Catalyst does not collect or store your credit card numbers or other similar financially related Personal Information and it isn’t exposed more than necessary. For more information about PCI DSS generally please visit https://www.pcisecuritystandards.org/about_us/.
  4. Transaction Data includes details about payments to and from you and other details of Catalyst products and services you have purchased from us.
  5. Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  6. Profile Data includes your Catalyst donations, Catalyst purchases or orders made by you, your interests, preferences, feedback and survey responses where applicable.
  7. Usage Data includes information about how you use the Catalyst website, products and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  9. Aggregated Data / Analytics Information. We also collect, use and share Aggregated Data. In an effort to improve visitors’ experiences on the Catalyst website, Catalyst gathers this Aggregated Data related to individuals’ website visits. This information is used solely to measure and improve our website and services and to better serve our members and customers. Catalyst uses aggregate statistical data to compile reports. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as Contact Data, Technical Data, and/or Marketing and Communications Data which will be used in accordance with this privacy policy. This analytics information so gathered is likely to include the following:
    1. Device and network specific information, such as your unique device identifier, operating system and version, the browser you use, your Internet service provider (ISP), and your IP address.
    2. Non-personal information, such as language, zip code, area code, location, and the time zone.
    3. Catalyst website visit information, such as the domain from which you came to our website or referring links, and details of how you use our website, including but not limited to what webpages you visit on the Catalyst website, as well as downloads, purchases, and orders during the duration of your visit. At times we will track user behavior over time during interactions with the site in order to pursue legitimate business interests, including, but not limited to, troubleshooting technical user issues with site services.
3. Sensitive Information.
  We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. Cookies and Browser “Do Not Track” Notice
  1. Catalyst may use cookies on your computer. A cookie is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity. Third parties that advertise on the Catalyst website do not have access to Catalyst cookies, but they may use their own cookies on your computer. Advertisers’ use of their cookies and device identifiers is subject to the advertisers’ own privacy policies. Catalyst does not correlate its use of cookies with your Personal Information.
  2. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information
  3. Catalyst does not respond to browser Do Not Track (“DNT”) Signals. Catalyst websites may utilize page tags or web beacons to track information related to user visits as a part of Catalyst data analytics processes and user experience customization as described below. Page tags are small pieces of Javascript embedded in webpages that collect data to help track web traffic on our website. Web beacons are very small, effectively invisible, graphic images we use to count and recognize users on our website. Such technologies enable us to improve and customize user experiences while users visit our website. Click here https://allaboutdnt.com/#adjust-settings for information on how you can opt out of such behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. Catalyst does not correlate its tracking activities through the use of page tags or web beacons with your Personal Information.
  4. Catalyst may employ third party data analytics firms to track and analyze traffic on the Catalyst website, to analyze visitor trends, to determine advertising effectiveness, browser types and usage trends, and to present targeted ads based on anonymous information collected through tracking. Catalyst’ third party analytics firms, as described in this section, do not receive your Personal Information.
  5. Third parties that may advertise on Catalyst websites may have content embedded that sets cookies on a visitor’s browser and/or tracks visitor information that a web browser visited a specific Catalyst website. Such information may contain a visitor’s IP address. Third parties may not collect identifying Personal Information from the Catalyst website unless you provide it to such third parties.
  6. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
5. Keeping Information Updated
  It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Security of Personal Information
Catalyst takes the security of your Personal Information very seriously. When your Personal Information is stored by Catalyst, we use reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction. Unfortunately, data transmission over public networks cannot be guaranteed to be one hundred percent secure. While Catalyst will use all reasonable means to protect your Personal Information, Catalyst cannot guarantee the security of your transmissions of such Personal Information, and you use the Catalyst website at your own risk. If you suspect your Personal Information has been compromised, please notify Catalyst Customer Service using the contact information provided below.
How we Collect Your Personal Information. We use different methods to collect data from and about you including through the following methods.
1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  1. apply for our products or services;
  2. create an account on our website;
  3. subscribe to our service or publications;
  4. request marketing to be sent to you;
  5. enter a competition, promotion or survey; or
  6. give us feedback or contact us.
2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
3. Technical Data from the following parties:
  1. analytics providers such as Google based outside the EU;
  2. advertising networks based inside OR outside the EU; and
  3. search information providers based inside OR outside the EU.
4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU.
How Catalyst Uses and Shares Your Information
1. General Information and Your Rights. Catalyst limits its use of your Personal Information to the stated purposes for which such information is collected. In some cases, Catalyst may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. You have the right to the following regarding your Personal Information transferred to Catalyst:
  1. To know the types of Personal Information Catalyst collects;
  2. To know the purposes for which it collects and uses your Personal Information;
  3. To know type or identity of third parties to which Catalyst discloses your Personal Information, and the purposes for which it does so;
  4. To access and update your Personal Information; and
  5. To know the choices and means Catalyst offers you for limiting the use and disclosure of your Personal Information.
2. Catalyst Services to Catalyst ID Holders.
  When you create a Catalyst ID, we may use information collected from technologies such as cookies, web beacons, and page tags, as described herein, to improve your experience of our website. For example, by saving information concerning the pages you visit and products you purchase, we will be able to provide you with information on other Catalyst goods and services that may be of interest to you. Furthermore, by creating an account with Catalyst, there is a possibility of receiving content from third parties through Catalyst, as discussed under Section 6.5, below.
  
  Based on the information we gather, we may use targeted advertising from third party vendors, customized to reflect your interests. For example, if you purchase certain materials from Catalyst, Catalyst may display advertisements from vendors of similar materials. To accomplish this, we may use cookies and other technologies in order to recognize your computer at the time we display an advertisement to you. Catalyst may tailor advertisements based on your use of our website, such as tracking the pages you visit, the searches you make, or the goods or services your purchase. Catalyst does not correlate activities described in this section with your Personal Information, and we will not provide advertisers with your Personal Information when you view a targeted advertisement. However, through your interaction with a targeted advertisement, you consent that an advertiser may infer that you meet certain targeting criteria for the display of the advertisement.
  
  In creating an Catalyst ID, and as a condition of having an Catalyst ID, you expressly consent to Catalyst’ use of your Personal Information and non-personally identifiable information as described in this section. Moreover, in using an Catalyst ID you expressly acknowledge and agree to our collection and use of such information as described in this section.
  
  You can opt-out of the use of your Personal Information as described in this section by deleting your Catalyst ID. To delete your Catalyst ID, please contact Catalyst Customer Service using the contact information provided below.
3. Other Catalyst Services.
  Catalyst may use your Personal Information to provide services to you upon your request. Such services may include sending you newsletters and publications, responding to your questions and comments, communicating with you concerning your purchases on the Catalyst website, emailing you updates concerning Catalyst products and services, and personalizing your visits to Catalyst website.
  
  You may opt-out of the use of your Personal Information as described in this Section by contacting Catalyst Customer Service using the contact information provided below.
4. Catalyst Internal Data Sharing
  Catalyst may also share your Personal Information with other Catalyst offices or Catalyst subsidiaries in the country in which you reside and in other countries.
5. Information Sharing with Third Parties
  1. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
  2. Catalyst may utilize third-party service providers that process your Personal Information solely on Catalyst’ behalf (“Agents”). When Catalyst transfers your Personal Information to its Agents, your Personal Information will be used only for limited and specified purposes. Catalyst will take reasonable and appropriate steps to ensure that its Agents process your personal information in a manner consistent with the organization’s obligations. Catalyst remains responsible and liable if the Agents that Catalyst engages to process your Personal Information on Catalyst’ behalf do so in a manner inconsistent with this Online Privacy Policy, unless Catalyst proves that it is not responsible for the event giving rise to the damage.
  3. Catalyst uses outside third parties to ship orders and financial service-oriented third parties to bill users for goods and services. All parties with which Catalyst shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy.
  4. Catalyst may partner with third parties to provide other specific services, including, but not limited to registration for Catalyst conferences and other Catalyst program and educational materials. When the user signs up for these services, we may share names, or other contact information that is necessary for the third party to provide these services. Catalyst may auto-populate forms utilized by these third parties with data contained in Catalyst managed cookies. These third parties are not allowed to use your Personal Information except for the purpose of providing these services. All parties with which Catalyst shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy.
6. Other Possible Disclosures.
  In addition to the other disclosures stated herein, Catalyst may share your information in the following ways:
  1. To comply with applicable laws, regulations, legal processes, or government enforced orders,
  2. To enforce applicable terms of service, protect our legal rights or defend against legal claims,
  3. To defend, prevent, take action, and otherwise address security or technical issues, as well as suspected or potential fraud,
  4. To guard against harm (whether actual or potential) to the legal rights, property or safety of Catalyst, our visitors or the general public as required or permitted by law.
International Transfers
1. We share your personal data within Catalyst. This will involve transferring your data outside the European Economic Area (EEA).
2. Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Catalyst Purposes In Using Personal Information

We have set out below, in a table format, a summary of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or member.	(a) Identity (b) Contact	Performance of a contract with you
To register you for Catalyst events, conferences and programs.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Financial (f) Transactional	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Inviting you to contribute content, or respond to social media communications (c) Managing Catalyst member services.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Financial (f) Transactional (g) User Contributed	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) User Contributed	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) User Contributed	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) User Contributed	Necessary for our legitimate interests (to develop our products/services and grow our business)

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer or member.

(a) Identity

(b) Contact

Performance of a contract with you

To register you for Catalyst events, conferences and programs.

(a) Identity

(b) Contact

(d) Marketing and Communications

(e) Financial

(f) Transactional

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(e) Financial

(f) Transactional

(g) User Contributed

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) User Contributed

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

(g) User Contributed

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

(g) User Contributed

Necessary for our legitimate interests (to develop our products/services and grow our business)

Data retention
1. We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Catalyst Email Uses
1. Catalyst never rents or sells email addresses to outside parties without your consent. Occasionally, you may wish to receive information or communication from a Catalyst affiliated entity. In that instance, you will be asked for permission to share your email address.
2. After you create an online account with Catalyst, you will receive information about Catalyst products, services, and educational offerings that relate to your areas of interest unless you choose to opt-out. If you have questions or concerns about Catalyst’ Online Privacy Policy or wish to no longer receive such offers (opt-out), please contact Catalyst Customer Service using the contact information provided below.
How to Access or Change Your Personal Information
1. To review or make changes to the content of your Personal Information, or to request that we limit the use of your Personal Information, you may make changes and updates by logging into your user profile and making such changes. Alternatively, you may request such changes by contacting Catalyst Customer Service using the contact information provided below.
2. In your request, clearly state what information you would like to have changed or updated. Catalyst will try to comply with your request as soon possible.
3. The deletion of Personal Information and other changes to the data retained by Catalyst as described above may result in the deletion or limitation of other services Catalyst provides, including, but not limited to, maintaining and making accessible Catalyst certification records. Catalyst may retain certain Personal Information to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce agreements.
Your Legal Rights. You have the right to:
1. Request access to your personal data (commonly known as a “data subject access request” under GDPR). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  1. If you want us to establish the data’s accuracy.
  2. Where our use of the data is unlawful but you do not want us to erase it.
  3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Nevada Opt Our Rights.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to the Contact listed below. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Your California Privacy Rights

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your personal information. However, Catalyst will not sell your Personal Information.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and services to you, if that difference is reasonably related to the value provided to our business by your personal information.

Verification
Catalyst will regularly self-assess its compliance with all applicable law regarding Personal Information that is received from the EU. Catalyst statement on verification and related self-assessment procedures is available to you upon request.
Recourse Mechanisms
Catalyst makes readily available independent recourse mechanisms by which your complaints and disputes are investigated and expeditiously resolved at no cost you. Please direct any inquiries or complaints regarding our compliance to the point of contact listed in the “Contact Us” section below. If we do not resolve your complaint within 45 days, you may submit your complaint free of charge to JAMS using this link: https://www.jamsadr.com/eu-us-privacy-shield. Catalyst has designated JAMS, an alternative dispute resolution provider in the United States. The JAMS dispute resolution process shall be conducted in English. A binding arbitration option will also be made available to you at your request if you qualify for such option, in order to address your complaints not resolved by any other means.
Notices of Changes to Privacy Policy
In the event of any change to the Catalyst Online Privacy Policy, notice of such changes will be posted on the Catalyst website. Any changes to this Online Privacy Policy will become effective when we post the revised Online Privacy Policy on the Catalyst website. Your use of the Catalyst website following these changes means that you accept the revised Online Privacy Policy.
Contact Catalyst
For any questions, comments, or further information concerning the terms of this Online Privacy Policy, or to request changes to your Personal Information, subject to such limitations as provided herein, please contact:

Catalyst Customer Service
[email protected]