VirnetX California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA.

Personal Information Collection, Disclosure, and Sale

For the purposes of this notice, Personal Information means 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, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

• Lawfully made available from government records.
• Deidentified or aggregated.
• Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve months since this notice was last updated, as well as the categories of sources from which that information was collected, and the categories of third parties with whom we shared Personal Information. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Category	We Collect	We Disclose	We Sell	Categories of Third Parties with Whom We Share Personal Information
A. Identifiers Examples: Name, internet protocol address, email address, account name, or other similar identifiers.	Yes	Yes	No	II, III, IV
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e) Examples: Name, telephone number, passport number, bank account number, credit card number, debit card number, or any other financial information.	Yes	Yes	No	II, III, IV
C. Characteristics of Protected Classifications under California or Federal Law Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.	No	N/A	N/A	N/A
D. Commercial Information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	Yes	No	II, III, IV
E. Biometric Information Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No	N/A	N/A	N/A
F. Internet or Other Electronic Network Activity Information Examples: A consumer’s interaction with an internet website, application or advertisement.	Yes	Yes	No	I, III, IV
G. Geolocation Data Example: Precise physical location.	No	N/A	N/A	N/A
H. Sensory Information Examples: Visual information. Uploaded user Icon	Yes	Yes	No	II, III, IV
I. Professional or employment-related information Examples: Job application or resume information, past and current job history, and job performance information.	No	N/A	N/A	N/A
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.	No	N/A	N/A	N/A
K. Inferences Drawn from Personal Information Examples: Consumer profiles reflecting a consumer’s preferences or characteristics.	Yes	Yes	No	III, IV

In the preceding twelve months, we have not sold any California resident’s Personal Information.

Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

1. Providing Services: Providing our services.
2. Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
3. Connecting Third Party Services: Facilitating the connection of third-party services or applications, such as social networks.
4. Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
5. Personalization: Personalizing your experience on our services such as presenting tailored content.
6. Sending Messages: Sending you text messages or push notifications.
7. Facilitating Payments: Facilitating transactions and payments.
8. Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
9. Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
10. Debugging: Debugging to identify and repair errors that impair existing intended functionality.
11. Transient Use: Short-term, transient use.
12. Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
13. Research: Undertaking internal research for technological development and demonstration.
14. Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
15. Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.

Collection of Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

1. You/Your Devices: You or your devices directly.
2. Users: Other users of our services.
3. Affiliates.
4. Analytics Providers.
5. OS/Platform Provider:: Operating systems and platforms.
6. Partners: Business Partners.
7. Public: Publicly accessible sources.

Disclosure of Personal Information

Pursuant to our Privacy Policy, we share your Personal Information with the following categories of third parties:

1. Analytics Providers.
2. Affiliates.
3. Vendors: Vendors and service providers.
4. Integrated Third Parties: Third parties integrated into our services.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with your name and email address, and we will follow up with you with any additional information we need to verify your identity.

Right to Opt Out. In some circumstances, you may opt out of the sale of your Personal Information. We do not sell your Personal Information.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, please use our Privacy Request form at https://help.virnetx.com/kb-tickets/new or send us an email via our Contact Information section.

Authorizing an Agent: To authorize an agent to make an opt-out request on your behalf, please send a written authorization signed by you and the authorized agent to us via the Contact Information section.

Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities, or you would like to exercise your privacy rights please email us at support@virnetx.com.