KENSINGTON CORPORATE PRIVACY POLICY

Latest update: January 5, 2026

At Travel Edge Company (USA) Inc. and Travel Edge Company (Canada) Inc. (together, “Kensington Corporate,” “we,” “us,” or “our”), we have a strong commitment to providing excellent service to all of our customers and visitors of our Websites, including respecting your concerns about privacy. We want you to understand what information we collect, and how we use and share it. That is why we encourage you to read this Privacy Policy before using our Websites.

As a provider of corporate travel management services, Kensington Corporate collects, uses, discloses, and otherwise processes personal information in connection with arranging, booking, administering, and supporting business travel and related services. This information may relate to: (i) individual travelers whose travel is arranged or managed through Kensington Corporate (each, a "Traveler"); and (ii) individuals who interact with us on behalf of a corporate customer or travel program, such as travel arrangers, administrators, account contacts, and other representatives (collectively, "Clients"). In most cases, Kensington Corporate processes Traveler personal information on behalf of Clients to arrange, book, administer, and support business travel and related services. In those contexts, the Client’s privacy practices and instructions as well as any applicable agreements with the Client may apply in addition to this Privacy Policy. In other cases, we determine the purposes and means of processing personal information for example in order to operate our Website and manage our business (including for security, compliance, analytics, and recordkeeping purposes), to process employment and contractor applications, and when individuals otherwise communicate or interact with us (for example, by email, phone, chat, or in-person).

Anyone who submits personal information to us should understand the nature of our services and that we may collect, use, disclose, and process personal information to provide and support travel management services and to operate our business. Your personal information may be shared with authorized third parties (such as airlines, hotels, car rental providers, travel technology providers, payment processors, online booking tools, global distribution systems, insurers, and other travel or service partners), including with parties located outside of your region, where necessary to fulfill travel arrangements, administer travel programs, comply with legal obligations, and otherwise for the purposes described in this Privacy Policy and any applicable agreement we have with your organization. Subject to applicable law, you may have the right to access and request correction of personal information we hold about you, and to withdraw or revoke consent where consent is the lawful basis for processing.

For more details on how we collect, use, and share personal information, we invite you to review our responses to frequently asked questions, below.

If you are a resident of California or Nevada, please see the sections specific to those jurisdictions at the end of this Privacy Policy.

1. What is this Privacy Policy and what does it cover?
2. What information do we collect and how?
3. Why do we collect your information?
4. How do we share your information?
5. How do we transfer your information?
6. How do we secure and keep your information?
7. What are your rights regarding your information?
8. Children’s privacy
9. How do you use Cookies?
10. How to unsubscribe to marketing communications?
11. How will you know if this Privacy Policy has changed?
12. How to contact us?
13. For Nevada Residents
14. For California Residents

This Privacy Policy applies to our website at https://www.kensingtoncorporate.com (the “Website”), any applications you make to join Kensington Corporate, the provision of our corporate travel management services, and any interactions with us by any means (collectively, “Services”).

Our Services may contain links to third-party websites, applications, or services (including services provided by Travel Suppliers). Please be aware that this Privacy Policy does not apply to any external platforms you may access through such links. These third parties may have their own privacy policies and practices, which we do not control. We strongly recommend reviewing their privacy policies to understand how your personal information may be collected, used, and shared.

If you are a Traveler whose travel is arranged through your employer or another organization’s travel program (including through a travel arranger, travel administrator, or other representative of that organization), please note that your personal information may be collected and processed by that organization and/or its authorized representatives in connection with arranging and administering your travel. In such cases, the organization’s privacy policy (and/or the privacy policy of any third-party platform they use) will govern their handling of your personal information. Kensington Corporate is not responsible for the privacy practices of third parties, including corporate customers and their representatives, operating independently of Kensington Corporate.

This Privacy Policy is incorporated into Kensington Corporate’s Terms of Use. To the extent permitted by applicable law, the disclaimers and limitations of liability set forth in the Terms of Use apply equally to this Privacy Policy. This includes, without limitation, any liability arising from or related to the collection, use, disclosure, or storage of personal information. Nothing in the Terms of Use or in this Privacy Policy is intended to, or shall be interpreted to, limit any rights you may have, or any obligations we may have, under applicable privacy, data protection, or consumer protection laws that cannot lawfully be limited or waived.

When using our Services, we may ask you to provide us with your information, including identification information that may be used to contact or identify you. In the corporate travel management context, some of this information is also provided to us by your employer, another sponsoring organization, travel arrangers or administrators, online booking tools, global distribution systems, and Travel Suppliers. You are responsible for ensuring that the information you provide to Kensington Corporate is accurate and up to date. If information is inaccurate or incomplete, we may be unable to provide the Services or complete bookings. Please see the table below for more details on the information we collect.

In addition, we collect personal information from candidates during the hiring process. Below is a summary of the personal information we collect and the purposes for which we may use it.

Kensington Corporate may collect sensitive personal information related to a Traveler’s travel arrangements (such as the Traveler’s dietary restrictions and other accessibility requirements) (“Sensitive Personal Information”) to help the Traveler obtain special accommodations for travel arranged by or through Kensington Corporate, but only if the Traveler submits such Sensitive Personal Information (either directly or indirectly through a trusted third party such as a Client or online booking tool). We use Sensitive Personal Information solely as reasonably necessary to arrange, manage and support the specific travel services requested or required (for example, to communicate necessary information to relevant Travel Suppliers so they can provide appropriate accommodations), to comply with applicable laws, and to exercise or defend legal claims. Access to Sensitive Personal Information is limited to personnel and service providers who need to know it for these purposes. If a Traveler does not want us to collect and use such Sensitive Personal Information, then the Traveler should not submit this information to us; however, this may affect our ability, or the ability of Travel Suppliers, to provide certain accommodations or services.

Please note that we may also collect and use your information for any other purpose permitted or required by law, or that is compatible with the purposes described above and disclosed to you at or before the time of collection.

If you provide us or our service providers with personal information about another individual in connection with the Services (including as a Client on behalf of a Traveler), you represent and warrant that you have obtained all necessary consents and authorizations from that individual to disclose such information, or that you are otherwise permitted to provide such information under applicable law. You further represent and warrant that you have the authority to permit us to collect, use, disclose, and otherwise process such information in accordance with this Privacy Policy.

By contacting us and requesting information, using our Services or otherwise providing us with your information, you consent to the collection, use or disclosure of your information in accordance with the purposes identified below, to the extent such consent is required by applicable law. In other cases, we may process your information where this is necessary to perform a contract with you or a Client, to comply with legal obligations, or for our legitimate business interests, as permitted by law. We may seek additional consent to use and disclose your information after it has been collected but before it is used or disclosed for a new purpose that is materially different from what was originally identified.

Kensington Corporate may use your information for the following purposes:

• To personalize and deliver travel services: We use your information to facilitate and manage travel arrangements (including without limitation any customer service issues that may arise or post-travel issues), ensure travel policy compliance, and analyze travel data in connection with the relevant travel program. We may also enable alternative travel service providers to assist you when needed. Where appropriate, we may share relevant information with trusted third-party travel providers or alternative service partners to ensure continuity of service when we are unable to fulfill a request directly.

• To provide, maintain, and improve our Services: We collect information to offer and improve our Services, including monitoring usage, personalizing your experience, remembering your preferences for future visits, enhancing our booking tools and traveler support, and maintaining the security and integrity of our systems.
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• To establish and maintain responsive relationships: We use your information to respond to inquiries, fulfill requests, and understand the needs and preferences of Travelers and Clients, including any special requirements.
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• For the performance of a contract: We use your information to fulfill our contractual obligations, including without limitation those with Travelers and Clients. This may involve making payments, collecting fees, providing travel arrangements, or supporting other services you have requested or agreed to, whether directly with us or through your employer or another organization.
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• To contact you: We may use your information to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications, regarding updates, administrative communications (such as changes to our terms, conditions, and policies), security alerts, notifications, travel disruptions, or other informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
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• To provide you with information and marketing: We may use your information to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, or other information, advertising, promotional or marketing communications that we believe may be of interest to you, unless you have opted not to receive such information. We do not use Sensitive Personal Information, government-issued identification numbers, or detailed travel document information for marketing purposes, and we use itinerary information for marketing only to the extent permitted by law and in connection with related or similar travel services (for example, trip enhancement offers) that we or your travel program may provide.
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• To manage your requests: We may use your information to attend and manage your inquiries and requests to us.
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• To deliver targeted advertising to you: We may use your information (primarily technical information, online identifiers, and interaction data) to develop and display content and advertising (and work with third-party vendors who do so) tailored to your interests and/or location and to measure its effectiveness, as further described in the “How do you use Cookies?” section below.
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• To conduct surveys and promotions: We may use your information to invite you to participate in surveys or promotional campaigns.
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• To manage, analyze and improve our business: We use data for audits, accounting, fraud and security monitoring, usage trend analysis, business management (including travel program analytics and reporting for Clients), and to evaluate and enhance our Services, marketing efforts, and overall user experience.
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• To process your application for employment: We may collect and use your information to assess your qualifications, verify your identity, conduct background checks, communicate with you regarding your application, and make hiring decisions.
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• For business transfers: We may use your information 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 information held by us about our Service users is among the assets transferred.
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• To aggregate or anonymize data: We may aggregate or de-identify personal information to generate statistical or analytical insights about our Services and business, in a form that does not reasonably identify you.
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• To meet legal and regulatory obligations: We may use your information to comply with applicable laws and cooperate with law enforcement or government authorities.
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• For other purposes: We may use your information for any other purpose disclosed to you at the time of collection, with your consent where required, or as otherwise permitted or required by applicable law.
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We may share your information in the following situations where necessary to fulfil the purposes identified above, including as set forth below:

• With Travel Suppliers: In order to complete the travel arrangements requested by the Traveler (or the Client), Kensington Corporate may input the Traveler’s personal information into a booking/operating system or provide the Traveler’s personal information to travel suppliers, such as airlines, hotels and rental car agencies, tour operators, insurance providers, internet booking engines or global distribution systems (individually and collectively, “Travel Supplier”). The Travel Supplier uses such personal information to aid in fulfilling the travel arrangements requested by a Traveler, such as for flights, lodging and rental car services, and for associated purposes such as security screening, fraud prevention, and loyalty program administration, in accordance with their own privacy policies and practices.
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• With Service Providers and Vendors: We may share your personal information with third-party providers who help us provide, operate, support, and enhance our Services. These providers may assist with maintaining our website and booking platforms, managing customer relationships, processing payments securely, analyzing usage data to improve user experience, delivering targeted advertising or general marketing information on our behalf, and optimizing our communications. They may also support backend functions such as infrastructure hosting, system performance monitoring, and integration of accounting platforms to ensure smooth financial operations.
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• With Clients: Kensington Corporate may share your personal information with Clients including to facilitate travel reservations, organize tours, provide travel program reporting and analytics, verify compliance with travel policies, and share relevant information about the Traveler’s arrangements. Clients’ handling of such information is subject to their own privacy policies and agreements with you.
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• Travel-Related Service Partners: Kensington Corporate may share your personal information with select third parties, such as other providers of travel services, for marketing purposes. For example, we may work with other travel/tour companies to provide you with the opportunity to purchase travel-related services suitable to your needs, such as destination experiences, insurance or ancillary services, in connection with your trip or travel program. If you are a resident of California or Nevada, please see the “For California Residents” and “For Nevada Residents” sections below for more information about your rights with respect to Travel-Related Service Partners.
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• For business transfers: We may share your information with an acquirer, successor or assignee as part of, or in connection with, any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
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• With Affiliates: We may share your information with our affiliates, including without limitation for purposes such as the provision of travel services, business development, strategic planning, marketing and service improvement, in which case we will require those affiliates to honor this Privacy Policy and any applicable legal requirements. Affiliates include our parent companies and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
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• With business partners: We may share your information with our business partners to offer you certain products, services or promotions in connection with our Services. Where those partners receive personal information for their own use, they are responsible for their own privacy practices and, where required by law, we will obtain your consent or provide you with an opportunity to opt out before sharing information for their independent marketing purposes.
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• With professional advisors: We may share your information to our legal, financial, accounting or other consultants to the extent necessary to operate our business and comply with applicable laws.
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• With law enforcement and other authorities: We may receive requests by authorities to access your information. We will validate that the request is legitimate before responding. When possible, we will advise you. We will only share what is strictly required.
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• Protection of Rights: Kensington Corporate may use and disclose personal information to: comply with a legal obligation, establish or exercise our legal rights, enforce our contracts or this Privacy Policy, assert or defend against legal claims (including in order to protect against legal liability), protect and defend Kensington Corporate's and its affiliates' rights or property, or take action against illegal or fraudulent activities or any other wrongdoing in connection with our Services or potential threats to the physical safety or well-being of any person including users of our Services or the public.
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• With other users: When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
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• With your consent: We may disclose your information for any other purpose with your consent.
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Your information may be held at our offices, and those of the third parties described above, as well as on computers or servers owned or managed by us or such third parties. Some of these third parties may be based in, access, or store your information outside of your region (for example, outside the province or territory in which you reside, or outside Canada, including in the United States or other jurisdictions). By submitting information to us, you consent to the communication of your information to, and the storage of that information, outside of the jurisdiction in which you reside, where such consent is required by law. While such information is outside of your local jurisdiction, it is subject to the laws of the jurisdiction in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other jurisdictions pursuant to local laws.

However, our practices regarding your information will at all times continue to be governed by this Privacy Policy. Where applicable, we comply with legal requirements providing adequate protection for the transfer of information to third countries.

If you would like more information about how we transfer your information, please contact us as set forth in the section below “How to contact us?”

We implement reasonable physical, administrative and technical safeguards designed to preserve the confidentiality, integrity and security of information under our control. However, information transmitted on the Internet and/or stored on systems attached to the Internet is not 100% secure, and no security can provide absolute protection. As a result, we do not ensure, warrant or guarantee the security or integrity of such information.

We retain your information only for as long as is necessary for us to fulfil the relevant purposes specified in this Privacy Policy and to comply with our legal obligations, resolve disputes, and enforce our agreements. We may apply different retention periods for different categories of personal information, depending on factors such as the type of information, the nature of our relationship with you (for example, Traveler, Client representative, or candidate), the length of your or your organization’s travel program, applicable legal or regulatory retention requirements (including tax, audit and corporate recordkeeping obligations), and the need to maintain records for security, fraud prevention or litigation purposes.

We take steps to ensure that only those who need access to your information to perform their duties have access to it

Under certain circumstances and subject to applicable data protection laws, supported by a written request and proof of identification, you may consult the personal information that we have collected, used or shared, and/or ask that it be corrected if it is inaccurate, incomplete or outdated, and/or withdraw your consent to our disclosure or use of personal information collected.

As required or permitted by law, you may be entitled to additional rights, including: (i) the right to control the dissemination of your personal information; (ii) the right to receive computerized personal information collected from you in a structured, commonly used and technological format and to have this information transferred directly to another organization, where technically feasible; (iii) the right to be informed of and submit observations regarding automated decision-making that uses your personal information and produces legal effects concerning you or significantly affects you, if any; (iv) the right to request information about data processing; and (v) any other rights recognized under the privacy laws of the jurisdiction where you reside.

Finally, you also have a right to lodge a complaint with a competent data protection authority, in particular in the country/territory where you normally reside, where we are based or where an alleged infringement of data protection law has taken place.

To exercise any of these rights, please contact us as set forth in the section below “How to contact us?” We may need to verify your identity and may request additional information where permitted by law. In some cases, we may refuse or limit your request where we are permitted or required to do so under applicable law, for example where honoring the request would reveal personal information about another individual or would interfere with legal or contractual obligations.

We do not knowingly collect personal information from children under the age of 14 on our Websites. If you are the parent or legal guardian of a child under 14 who has provided us with personal information, please contact us as set forth in the section below “How to contact us?” to ask us to stop using or to delete that information.

How do you use Cookies?

Our Website may utilize cookies. Cookies enable us to monitor website traffic patterns and serve you more effectively. When you visit our website, our servers may automatically recognize certain information about you. Cookies may tell us things like whether you have visited our website before and which of our website’s features you used. The information collected from cookies allows us to provide better customer service to you and helps us improve the features of our website.

We may also use web beacons or “pixels” that collect IP address, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data described in Section 2 above.

You may opt out of or disable cookies. Most computer systems and web browsers offer privacy settings and options that allow users to block, delete or disable cookies, or to receive a notice before certain cookies are stored. Certain features, services, products, content, or benefits of our website require that you provide us with certain information, including some types of personal information or information obtained from cookies, web beacons, and similar tracking technologies (for example, cookies that are strictly necessary for the website to function or to keep you logged in). If you do not wish to provide us with certain information or disable cookies, you may be unable to obtain certain features, services, products, content, or benefits of our Website.

If you use our mobile application or access the website from a mobile device, we may collect additional information, such as device information (such as your mobile device ID, model and manufacturer), operating system, version information, IP address, carrier-related information, including the name of your wireless carrier, and IDs related to the cell phone hardware in your phone, as well as the network to which the device is connected, mobile phone number, application-specific and instance-specific identifiers, and location information, as further described Section 2 above.

Analytics: We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/,www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Advertising: We may partner with third-party advertising companies that serve advertisements regarding goods and services that may be of interest to you when you access and use other websites or online services. You may receive advertisements based on information relating to your access to and use of our services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags) or use similar technologies (such as mobile advertising identifiers). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop, and to provide you with more relevant ads. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.

If at any time you wish to stop receiving marketing communications from us, we include an unsubscribe mechanism in all of our marketing emails or you can contact us as set forth in the section below “How to contact us?”

Please keep in mind that, if you choose not to receive marketing communications, you will continue to receive transactional or services-related communications related to reservations or other services that you have requested on our Website.

How will you know this Privacy Policy has changed?
From time to time, we may update this Privacy Policy. Any changes will be effective when we post the revised Privacy Policy. This Privacy Policy was last updated as of the effective date listed at the top.

How to contact us?

If you have questions concerning this Privacy Policy or the practices on our Websites, you may contact our Privacy Officer at privacy@rangegroup.com.  

Nevada residents may submit a request directing us to not sell personal information we maintain about them. If you have any questions about this, or to exercise this right, please contact privacy@rangegroup.com.

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months:

(1) We collected the following categories of Personal Information:

1. Identifiers, such as name, contact information, online identifiers, passport and other government ID numbers;
2. Personal information, as defined in the California customer records law, such as name, contact information, signature, payment card number, government-issued ID numbers, medical, health insurance, insurance information, and education and employment information;
3. Characteristics of protected classifications under California or federal law, such as sex and marital status;
4. Commercial information, such as transaction information and transaction history;
5. Internet or network activity information, such as browsing history and interactions with our website;
6. Geolocation data, such as device location and IP location;
7. Audio, electronic, visual, and similar information, such as call and video recordings;
8. Professional or employment-related information, such as work history and prior employer; and
9. Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.
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We collect this Personal Information from you and from other categories of sources: joint marketing partners, when they share the information with us.

As described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment and vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

(2) We disclosed the following Personal Information to third parties for our operational business purposes:

1. Identifiers, such as name, contact information, online identifiers, passport and other government ID numbers;
2. Personal information, as defined in the California customer records law, such as name, contact information, signature, payment card number, government-issued ID numbers, medical, health insurance, insurance information, and education and employment information;
3. Characteristics of protected classifications under California or federal law, such as sex and marital status;
4. Commercial information, such as transaction information and transaction history;
5. Internet or network activity information, such as browsing history and interactions with our website;
6. Geolocation data, such as device location and IP location; and
7. Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.
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We share Personal Information with our service providers, third-party sponsors of sweepstakes, contests and similar promotions, and our business partners.

For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, applicable law may give you the right to request that we:

(1) Disclose to you the following information covering the 12 months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;
• The categories of Personal Information about you that we sold and the categories of third parties to whom we sold such Personal Information (if applicable); and
• The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
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(2) Delete Personal Information we collected from you. To make a request for the disclosures or deletion described above, please contact us in accordance with the “How to Contact Us?” section above. We will respond to your request consistent with the CCPA. In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident.

(3) Opt you out of any future “sale” of Personal Information about you by emailing privacy@rangegroup.com. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.