You can update your preferences and information, or if you have any questions or concerns about our use of your personal information, by contacting us through any of the methods listed below:
Phone: 833-741-5868 (Toll-free)
Email:   privacy@hginc.com

When you visit the Site or use our services, HGI may collect and store personally identifiable information, such as your name, address, and email address. The information that we collect and store about you depends on the page you visit and the services in which you elect to participate. We use this information to operate our services, improve the quality of our services, offer you opportunities we think will interest you, and better tailor the advertising you see from us to suit you. This information is not shared with anyone outside of HGI except as provided in this Privacy Notice or as explained at the time the information is collected. The information we collect can include personal information (as described below) or non-personal information, which is information that does not identify or relate to an individual.

Personal information is information that identifies, relates to, describes, can reasonably be associated with, or can reasonably be linked to an identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We collect information through any correspondence that you provide to us whether through email, mail, phone calls, or through our Site or services. We may also collect personal information from other sources, as described below.

In addition, we may also collect personal information about you from third parties in connection with the Site, including from the following sources:

• Service providers (e.g., data hosting providers)
• Data analytics service providers
• Email and other communications service providers
• Promotional partners
• Social media platforms
• Conferences.

If we combine or associate information from other sources with personal information that we collect through the Site, we will treat the combined information as personal information in accordance with this Privacy Notice.

Information we collect

We may collect the following categories of personal information from you, depending on your interactions with the Site and the choices you make, as further described in the chart below:

Category	Data Types
Identifiers	Name, email address, shipping postal address, billing postal address, work address, telephone number, and Internet Protocol (IP) address.
Payment and Purchasing Information	Financial information provided by you, including name, billing and shipping address, payment information, and other financial data.
Employment-Related Information	Information you provide when applying for employment with HGI, such as education information, professional certifications, work eligibility status, and current and past employment history.
Interactions	Records of transactions and other information you post or otherwise submit to us, including emails or other communications you provide to us.
Internet / Electronic Network Activity	Browser History	Data about the webpages you visit, including without limitation web browser specifications, website visits before accessing the Site, and website visits after leaving the Site.
	Device, Connectivity, and Configuration Data	Data about your device and nearby networks, including internet connection information, computer equipment information, regional and language settings.
Demographic Data	Data about you such as your business or company information, professional or personal reference contact information, and other data reflecting your preferences for the Site.
Third-Party Social Network Service(s)	If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with the Site, we may receive your personal information and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts through those services. Some social networking services will facilitate registration or enhance or personalize your experience on the Site. This includes if you “follow,” “like,” or link your social networking account to the Site. Your decision to use a social networking service in connection with the Site is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available by reviewing privacy policies of those providers and/or modifying your privacy settings directly with those networking services.

We also collect anonymized and aggregated information through Google Analytics that may be created or derived from your usage of our Site for purposes that include data analysis and improving our Site. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners

How we use your information

Our legal basis for using your information as described above is a legitimate basis.  In relying on legitimate interests as the reason for processing your information, we carry out a balancing exercise to make sure your rights as an individual are not impacted unnecessarily.

We consider that it is reasonable for us to process your personal information for the purposes of our legitimate interests when, on balance, (a) we process your personal information only so far as is necessary for such purpose, and your rights and freedoms do not outweigh such purposes, and (b) it can be reasonably expected for us to process your personal information in this way. In most cases, the information is being processed for your benefit as well as ours.

We have a legitimate business interest in processing your personal information where:

• We need the information to respond to your inquiries or requests (g., to add you to our email list when you have subscribed); or
• We would be unable to provide our Site without processing your information.

We also process personal information for such legitimate interests as further detailed in the chart below:

Collection Type	Description	How We Use Information Collected
Newsletter Subscription Information	You may provide your email address in order to receive our newsletter via email.	To contact you with newsletters, marketing or promotional materials and other information that may be of interest to you.
Customer Service Information	This may include any information that you choose to provide, whether by phone, email, mail, or chat, to our customer service representatives or other HGI employees or Representatives (as defined below).	To provide, maintain, operate, personalize, and improve the Site and services. To evaluate and improve the content of the Site. To respond to your questions and requests. To provide customer support. To allow you to participate in interactive features of the Site when you choose to do so.
Demographic Data	We may collect such personal information when you make a purchase, contact us, and respond to our communications to you. Demographic data may include data about: Your business or company information; Your professional or personal reference contact information; and Other data reflecting your preferences for the Site.	To provide, maintain, operate, personalize, and improve the Site. To evaluate and improve the consent of the Site. To provide customer support. To monitor the usage of the Site. To gather analysis and assess trends and interests.
Payment and Purchasing Information	This includes any information that you choose to provide when conducting financial transactions on the Site or through our services, including information we receive from vendors or service providers, such as payment processors.	To provide you with services. To process your transactions. To respond to your questions and requests. To provide customer support. To provide you with recent information about a transaction.
Employment-Related Information	This includes any information that you choose to provide when applying for employment with HGI, including information you may provide to our third-party employment service providers.	To enforce our agreements, terms, conditions, and policies. To prevent or investigate fraud. To evaluate eligibility for employment. To determine employment decisions.
Third-Party Data	This may include both personal information and non-personally identifiable information from our partners, vendors, data brokers, or public sources.	To provide, maintain, operate, personalize, and improve the Site. To monitor the usage of the Site. To gather analysis and assess trends and interests. To work with our service providers who perform certain business functions or services on our behalf. To provide you with advertising content in which we think you will be interested. As part of this customization, we may observe your behaviors on the Site or on other websites.
Anonymized Information	We may use anonymized and aggregated information that may be created or derived from your personal information or usage of the Site for purposes that include data analysis, improving the Site, advertising, and developing new features and functionality within the Site.	To provide, maintain, personalize, and improve the Site. To monitor the usage of the Site. To prevent or investigate fraud. To gather analysis and assess trends and interests. To conduct aggregate or research analysis to enhance, protect, and make informed decisions on the Site. To detect, prevent, and address technical issues. To enforce agreements, terms, conditions, and policies. To help maintain the safety, security, and integrity of the Site and technology assets.
Feedback, Surveys, or Contests	We may offer you the opportunity to participate in online surveys, solicitations, or contests. Participation in surveys, solicitations, or contests is completely voluntary. Therefore, you have a choice as to whether to disclose any information.	To notify contest winners and award prizes. To provide, maintain, personalize, and improve the Site. To gather analysis and assess trends and interests. To conduct aggregate or research analysis to enhance, protect, and make informed decisions on the Site.
Usage Information	This can be personal information and non-personally identifiable information that may be collected about you when you are using the Site, and this may include: Information about your interactions with the Site, which includes the date and time of any information you enter into the Site and your interactions with other users of the Site and what content or features you interacted with. Technical data which may include URL information, cookie data, web beacons, web pixels, clickstream information collection, and other tracking technology information, your IP address, the types of devices you are using to access or connect to the Site, unique device IDs, device attributes, network connection type (e.g., Wi-Fi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system. Further details about the technical data that is processed by us can be found below. The Site uses cookies, unique identifiers, and similar technologies to collect information over time and across different websites when you use or visit the Site. We or our third-party partners use common tracking tools to collect information about the pages you view, the Site functions that you access, the buttons and icons you click, and to remember your login information and Site settings to make it easier and more efficient for you to use the Site, and to provide advertising content that we think may be of interest to you. For more information about our use of cookies, pixels, and web beacons, please see the “Tracking Technologies and Third-Party Advertisements” section below and as detailed in our cookie preference pop-up. We or our third-party partners may use invisible pixels or beacons on the Site to count how many users access or use certain pages, features, or content.	To improve our content and the products, services, materials, and other content we make available through the Site. To optimize the display of the Site on your device. To provide, maintain, personalize, and improve the Site.  To provide customer support. To monitor the usage of the Site. To allow you to participate in interactive features of the Site when you choose to do so. To gather analysis and assess trends and interests. To enforce our agreements, terms, conditions, and policies. To detect, prevent, and address technical issues. To prevent or investigate fraud. To provide you with advertising content in which we think you will be interested. As part of this customization, we may observe your behaviors on the Site or on other websites. To help maintain the safety, security, and integrity of the Site and technology assets. To investigate complaint and potential violations of our policies.

If we wish to process your existing information for a new purpose other than as stated above, we must inform you of that further processing and provide information surrounding your information’s use as necessary to provide the Site to you and to comply with a request to be added to our email list.  In addition, if we communicate with you for marketing or other promotional purposes, via email, notifications or other messages, we do so based on your consent.

Tracking Technologies and Third-Party Advertisements

Third parties, including advertisers and analytics companies, may collect information, potentially including personal information, about your activities over time and across different websites when you use our Site. Such third parties may provide HGI with data collection, reporting, ad response measurement, and other analytical information. Such third parties may also assist HGI with digital delivery of relevant marketing messages and advertisements.

Cookies. Cookies are small data files that are downloaded onto your computer or mobile device when you use the Site, which are unique to your device or account. Cookies make it easier for you to use the Site by saving your preferences so that we can use these to improve your next and subsequent visits to the Site. Cookies help us learn which areas of the Site are useful and which areas need improvement.

You can choose whether to accept certain cookies by changing the settings on your browser or device. Each browser has its own methods for doing this. For detailed instructions on how to disable, block or delete cookies in your browser, consult your browser’s help files or visit How to Manage Cookies. Please bear in mind that if you choose to disable this function, your experience with the Site may be impaired and some features may not work as they were intended. When we use cookies or other similar technologies, we may set the cookies ourselves or ask third parties to do so to help us.

You can opt out of non-essential cookies by adjusting your cookie preferences or by following the instructions in our cookie preference pop-up. Our Sites honors Global Privacy Control signals. Global Privacy Control is a browser tool that you can use to inform websites of your opt-out preferences. To set up Global Privacy Control, you can visit the Global Privacy Control page.

Please note that the Site is not set up to respond to Do Not Track (DNT) signals, but it does respond to browser cookies settings. You may opt-out from receiving personalized advertising from some third parties by visiting here. Please note that these choices will not opt you out of receiving advertisements. You will continue to receive generic advertisements.

Pixels, Web Beacons. We or our third-party partners may use invisible pixels or beacons on the Site to count how many users access or use certain pages, features or content. This information is collected and reported in the aggregate. We may use this information to improve our current Site offerings, develop new products or services, and target information to you that may be helpful and useful to you based upon your use of the Site.

In connection with our Site or services, we may share your personal information with the following types of recipients and for the following reasons:

Categories of Recipients	Reasons for sharing
Service providers	Service providers We use service providers to operate our software and infrastructure, in particular providers which host, store, manage, and maintain our Site, its content and the data we process. This includes our hosting and information security service providers.
Corporate affiliates	We may share your personal information with corporate affiliates including corporate parents, subsidiaries, other affiliated entities and associated entities, and customers and clients.
Marketing Service Providers	We use marketing service providers to communicate and interact with you.
Data analytics providers	We will share your personal information to create general data analytics regarding usage of our Site on an aggregate basis and without personal identifiers. As noted above, we use Google Analytics, a service provided by Google, Inc., to gather information about how you and other users engage with our Site. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners
Law enforcement and government authorities	We will share your personal information with third parties where required by law (including to respond to valid legal process such as a search warrant or a court order), where it is necessary in connection with our Site or where we have another legitimate interest in doing so.
Other legal or regulatory authorities	We will share your personal information for us to comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using user purchases in the aggregate, including revenues generated in connection with our regulatory tax requirements).
Buyer or successor of our business	We reserve the right to disclose and transfer all information (including personal information) we collect or maintain, including information related to our Sites, to a subsequent owner, co-owner or operator of one or more of the Sites or in connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process. We will share your personal information with any buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of title.
Other third parties	We may share your personal information with other third parties where you expressly request or authorize us to disclose your personal information.

In addition, we will disclose information about you:

• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• If this is necessary to protect the vital interests of a person or the public;
• To protect our property, services and legal rights;
• To prevent fraud against HGI, our Site, our affiliates, customers, product users, or business partners; or
• To support auditing, compliance, and corporate governance functions.

Most, if not all, of the third parties with whom we may share your personal information are located and store your information in the United States, although some may store your information outside of the United States. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We implement reasonable security measures designed to reduce the risks of loss, misuse, unauthorized access, disclosure or alteration of your personal information. While we are committed to protecting your personal information, please note that information communicated over the Internet is never 100% secure. Any transmission of personal information is at your own risk. By using our Site, you acknowledge and accept these risks. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us or that are otherwise provided to us and we cannot be responsible for the theft, destruction, or inadvertent disclosure of information. Any transmission of information is at your own risk.

We may store your personal information as long as you use our Site or services and for legitimate business purposes.

We may store your personal information following completion of transactions with you to the extent required to comply with our legal, accounting, or reporting requirements (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. Additionally, we may continue to store your personal information contained in our standard back-ups. Following termination or deactivation of any account you may create, we may retain your personal information for a reasonable amount of time for archival purposes. Furthermore, we may retain and continue to indefinitely use your personal information contained in your communications to other users.

We also will retain Usage Information (as described above) for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when Usage Information is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain Usage Information for longer periods.

Upon your request, we will delete or de-identify your personal information unless we are legally required or allowed to maintain such personal information.

Our Site may provide links to third-party websites that we do not control and with which our connection may only consist of a hyperlink (“Linked Sites”). We cannot be held responsible for third parties’ privacy practices or content provided on these websites. If you click on one of these links, please understand that you are leaving our Site and any information you provide will not be covered by this Privacy Notice. All Linked Sites are provided only because they may be of interest to users of the Site or offer a service for your convenience. The fact that we offer such links should not be construed in any way as an endorsement, authorization, or sponsorship of that Linked Site or its content, products, or services. Please read that website’s privacy policy before providing any information.

You acknowledge and agree that HGI has no responsibility for the accuracy or reliability of information provided by or through Linked Sites. HGI does not author, edit, or have any responsibility to monitor these Linked Sites. You should refer to the separate terms of use, privacy policies, and other rules posted on a Linked Site before you use them. You acknowledge that we shall not be responsible or liable for any damage or loss caused or alleged to be caused by, or in connection with, your reliance on any information, any good, any service, or any other material provided through a Linked Site. You bear all risk associated with the use of the Linked Sites, third party services, and your correspondence or business dealings with third parties (including any advertisers) found on or through the Site. We reserve the right to terminate such links at any time.

Our Site is not directed to anyone under the age of eighteen (18) years (“Children” or “Child”). By using our Site, you represent that you are at least eighteen (18) years old. If you do not meet this age requirement, then you must not access or use our Site.

We do not knowingly collect information from anyone under the age of eighteen (18), and we do not target the Site or our services to Children. If you are under the age of eighteen (18) years old, please do not use our Site and do not provide any information to us. For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of thirteen (13), please visit the Federal Trade Commission’s website https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions.

If you think we have collected information from a Child through our Site, please contact us through one of the methods listed under “How to contact us” above. If we learn that we have collected the information of a Child, we will take reasonable steps to remove that information from our servers.

To the extent that you provide or transmit any information, including, but not limited to, any personal information and any information that identifies any other individual (including without limitation name, email address and/or telephone number), to HGI or our third-party service or data providers, licensors, or distributors (“Representatives”) through the Site, you warrant that (a) you are providing or obtaining only your own information or the information of others which you are authorized to provide to third parties and/or obtain from third parties on their behalf; and (b) the use of such information by HGI and its Representatives will not infringe upon or misappropriate the intellectual property rights or otherwise violate the rights of any third parties.

This Privacy Notice shall be construed and governed under the laws of the United States and State of California (without regard to rules governing conflicts of laws provisions). You agree that venue for all actions, arising out of or relating in any way to your use of our Site, shall be in federal or state court of competent jurisdiction located in San Diego County, California, within one (1) year after the claim arises. Each party waives any objections based on forum non conveniens and waives any objection to venue of any action instituted hereunder to the extent that an action is brought in the courts identified above.

We store your personal information in the United States or other locations outside your home country. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country. If you are visiting our Site or using our services from outside of the U.S., please note that you are transferring information about you, including personal information, to a country and jurisdiction that may not have the same data protection laws as your country of residence. Because of the nature of our services, you may not have the same rights regarding your personal information that you would have interacting with a company in your jurisdiction. By providing us with personal information, you consent to the transfer of information about you, including your personal information, to the U.S. and other countries and the use and disclosure of information about you, including your personal information, as described in this Privacy Notice. We may store, access or otherwise process personal information outside of the U.S. as well.

If you are located in a country outside the U.S. and submit personal information to us, you consent to the general use and disclosure of such information as provided in this Privacy Notice and to the transfer and/or storage of that information to the U.S. and other countries outside your home country.

You have choices about how we use your personal information to communicate with you.  You can opt-out from receiving future marketing communications from us at any time by:

• Using the unsubscribe function in the email you receive from us; or
• Contacting us as set forth under “How to contact us” above.

Depending on where you live, you may have the following rights with respect to your data under certain circumstances, which may include the following:

• The right to request access to your personal information and the following information regarding our use of your personal information:
  • The purpose of such use
  • The categories of your personal information that we have used
  • Who we have disclosed your personal information to
• The right to request us to erase your personal information when we no longer need such data in connection with our Site or our services.
• The right to request us to correct any inaccurate personal information concerning you. You may also update or change your information under your account settings.
• The right to withdraw consent to our use of personal information, if we are relying on consent to use your personal information.
• The right to request us to restrict our use of your personal information (e.g., suspend our use of your personal information).
• The right to object to our use of your personal information where we are not using it to perform services you have requested from us.
• The right to receive a copy of your personal information.
• The right to lodge a complaint with the supervising authority of your country.

If you want to exercise any of the rights listed above and you are a resident of a jurisdiction providing you such rights, please contact us through one of the methods listed in under “How to contact us” above.

Please note that in order for us to verify certain requests (including verification of your identity, residency, and – for requests made on behalf of someone else – your relationship with the individual on whose behalf the request is being made), you may be required to confirm information that we have on file for you including email address, phone number, full name, address and other personal information. We reserve the right to deny a request if the identity or authority of the requesting party cannot be confirmed.

We will confirm receipt of your request within ten (10) business days and may request additional information necessary to verify that you are permitted to make the request. We will respond to any verifiable request within thirty (30) calendar days of receiving it, subject to delays and exclusions permitted by law. If we require more time to respond, we will let you know the reason why and the extension period in writing. If you have a password-protected online account with us, we may respond via that account. If you do not have an online account, we will use the email address or postal address you provided to us when making the request.

In certain cases, a request may be denied. For example, businesses are not required to delete personal information if it is necessary to complete a transaction, is reasonably used for an ongoing business relationship, or is used internally in a lawful manner that is compatible with the context in which the individual provided the information. If we deny your request, we will explain why we denied it. If we deny a request for information, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you for exercising any of your privacy rights, including, but not limited to, by:

• denying goods or services;
• charging different prices or rates for goods and services, including through the use of discounts or other benefits or imposing penalties;
• providing a different level or quality of goods or services; or
• suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. We may, however, charge a different price or rate, or provide a different level or quality of goods or services, if that difference is related to the value provided by your information.

If the jurisdiction in which you reside gives you the right to appeal, you can appeal our denial of any requests to exercise any of the rights described below through one of the methods in the “How to contact us” section.

We do not sell personal information for monetary consideration. We use cookies and tracking technologies as described above in the “Tracking Technologies and Third-Party Advertisements” section of this Privacy Notice and in our cookie preference pop-up. We also may disclose information about you to advertising providers in order to deliver you targeted advertisements across the internet as described in this Privacy Notice,

Certain of our disclosures may be considered a “sale” or “sharing” of personal information under state privacy laws, including California Consumer Privacy Laws (defined further below). Under those more expansive definitions, we have “sold” or “shared” the following categories of personal information in the past twelve (12) months:

Categories of Personal Information Sold/Shared in the Past 12 Months	Categories of Recipients
Identifiers	Marketing service providers; advertising networks; data analytics providers
Interactions	Marketing service providers; advertising networks; data analytics providers
Internet / electronic network activity	Marketing service providers; advertising networks; data analytics providers
Geolocation data	Marketing service providers; advertising networks; data analytics providers
Demographic data	Marketing service providers; advertising networks; data analytics providers

Some U.S. states have privacy laws that require specific disclosures or rights. If you reside in California, Nebraska, or Texas and are a “consumer” (as contemplated by the privacy laws of those states), certain of the below sections may apply to you.

If you are a resident of California, the laws of California provide you certain rights regarding your personal information. This includes rights afforded to you pursuant to the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, “California Consumer Privacy Laws”).

Shine the Light.  You have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at the address provided in the “How to contact us” section. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

CA Personal Information. The California Consumer Privacy Laws define personal information as 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 (“CA Personal Information”). CA Personal Information does not include: (1) De-identified or aggregated information; (2) information that is lawfully made available from federal, state, or local government records, or information that HGI has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience; and (3) information excluded from the California Consumer Privacy Laws, such as financial information covered under the Fair Credit Reporting Act (FCRA) or Gramm-Leach-Bliley Act (GLBA).

Categories of Information We May Collect and Disclose. The following chart provides information about the types of CA Personal Information we may collect, the sources of the information, the purposes for which we may use the information, whether the information has been disclosed for a business purpose, and the categories of third parties with whom we may have shared this information in the last twelve (12) months.

Type of CA Personal Information	Categories of Sources	Business or Commercial Purposes for Collection	Disclosed for a Business Purpose?	Third Parties to whom Disclosed for Business Purpose
Identifiers This may include but is not limited to: Contact information, real name, postal address, email address, telephone number, social media usernames, or other similar identifiers.	Directly from you; From our Sites as defined in our Terms of Use; Vendors; Data brokers; Social media platforms and networks; and government agencies.	To provide you with services and for internal purposes.	Yes	Internet service providers; analytics providers; advertising networks; professional services providers; government agencies; and affiliates
Internet and Electronic Network Activity Information This may include but is not limited to: browsing history, search history, and information regarding your interaction with our website or advertisements.	From our Sites as defined in our Terms of Use; vendors; and social media platforms and networks.	To provide you with services and for internal marketing analytics.	Yes	Internet service providers; analytics providers; advertising networks; professional services providers; government agencies; and affiliates
Location Data This may include but is not limited to: device location.	From our Sites as defined in our Terms of Use.	To provide you with services and for internal purposes.	Yes	Internet service providers; analytics providers; and advertising networks;
Commercial Information This may include but is not limited to: transaction information, records of service history, and service tendencies.	Directly from you; website cookies; vendors; data brokers; social media platforms and networks; and government agencies.	To provide you with services and for internal purposes such as analytics.	Yes	Internet service providers; analytics providers; advertising networks; professional services providers; government agencies; and affiliates
Audio, Electronic, or Visual Information This may include but is not limited to: audio recordings, and other electronic communications.	Directly from you; vendors; social media platforms and networks; and government agencies.	To provide you with services, complete transactions, for internal marketing analytics, and to defend and/or pursue legal rights of HGI or others as may be applicable.	Yes	Professional services providers; government agencies; and affiliates
Inferences from CA Personal Information Collected This may include but is not limited to: creating consumer profiles reflecting preferences and predispositions.	The original sources are the above enumerated sources of the underlying data that is compiled.	To provide you with services, for advertising and for internal reporting and analytics purposes.	Yes	Analytics providers; advertising networks; and affiliates

Your California Consumer Privacy Law Rights

You may have certain rights with respect to CA Personal Information that we have collected and used under certain circumstances, including the below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Information. You can request that we provide you the following information regarding our use of your CA Personal Information:

• The categories of your CA Personal Information that we have collected
• The purposes for which we have collected or used such CA Personal Information
• The categories of sources for the CA Personal Information we have collected about you
• The categories of third parties with whom we have disclosed your CA Personal Information
• If we have disclosed your CA Personal Information for a business purpose, a list identifying the CA Personal Information categories that each category of recipient obtained
• If we have sold your CA Personal Information, a list identifying the CA Personal Information categories that each category of recipient purchased

Access. You can request that we provide you a copy of your CA Personal Information that we have collected in the past twelve (12) months.

Correction. You can request that we correct any inaccuracies in your CA Personal Information. HGI will use commercially reasonable efforts to correct the identified inaccurate information upon receiving a verifiable request.

Deletion. You can request that we delete your CA Personal Information collected in the past twelve (12) months when we no longer need such data in connection with our business (subject to certain exceptions that may apply under applicable law).

Opt-Out of Sale or Sharing. Under California Consumer Privacy Law, you have the right to opt out of the sale or the disclosing of your CA Personal Information for purposes of cross-context behavioral advertising (“sharing”). For clarity, however, we do not “sell” CA Personal Information for purposes of California Consumer Privacy Law.

Limit Use of Sensitive Personal Information. You have the right to limit the use and disclosure of your “sensitive personal information” obtained by HGI.

Right to Non-Discrimination. If you choose to exercise your privacy rights under the California Consumer Privacy Laws we will not charge you different prices or provide different quality of services unless those differences are related to your CA Personal Information or otherwise permitted by law.

If you are a California resident where one or more of these rights are granted to you under applicable law, and you wish to exercise any such rights listed above, you may exercise your privacy rights by visiting HERE or by calling this toll-free number: 833-741-5868

Only you, or an agent legally authorized to act on your behalf, may make a verifiable consumer request related to your CA Personal Information (“California Consumer Request”). Please understand that we are required to verify your California Consumer Request and may require you to provide some information to enable us to carry out such verification. We will deny requests from agents that do not submit proof of legal authorization to act on your behalf. To verify that an agent has legal authority to act for you, we may require a copy of a power of attorney or require that you provide the agent with written permission and verify your own identity with us. We cannot respond to your California Consumer Request or provide you with CA Personal Information if we cannot verify your identity or authority to make the California Consumer Request and confirm the CA Personal Information relates to you.

When you, or someone legally authorized to act on your behalf, make a California Consumer Request, you can expect the following:

• We will verify your identity. You will need to provide us with certain information so that we can verify that you are who you say you are. Which information is required may depend on the type and sensitivity of information subject to the California Consumer Request.
• We will respond to your California Consumer Request within the legally required amount of time. If necessary, we may need additional time to respond where allowed by law, but we will reply either way within the legally required period and, if we need an extension, we will explain why.
• In certain cases, a California Consumer Request may be denied. For example, if we cannot verify your identity or if providing you information could create an unreasonable risk to someone’s security (for example, we do not want very sensitive information disclosed inappropriately). If we deny your California Consumer Request, we will explain why we denied it.

Making a California Consumer Request does not require you to create an account with us. We will only use CA Personal Information provided in a California Consumer Request to verify the requestor’s identity or authority to make the California Consumer Request.

Only California residents can make a California Consumer Request. A California resident is a person who currently lives in California or is domiciled in California but is outside of the state for a temporary or transitory purpose.

Nebraska residents have the following rights:

• Right to access and data portability. The right to confirm whether we are processing your personal information, to access your personal information, and to request that we provide you a digital copy, if available, of your personal information that you previously provided to us.
• Right to correct. The right to request that we correct any inaccurate personal information we maintain about you.
• Right to deletion. The right to request that we delete certain personal information that we have collected from you, subject to our right to maintain your personal information for specific purposes permitted under applicable state law.
• Right to opt-out. The right to opt-out of sales of your personal information, the use of your personal information for targeted advertising, or the use of your personal information for “profiling” in furtherance of decisions that impact a legal or similar right. We do not engage in “profiling” to make decisions about consumers that impact legal or similar rights, so there is no need to opt-out.
• Right to appeal. The right to appeal a denial of a privacy rights-related request.

Texas residents have the following rights:

• Right to access and data portability. The right to confirm whether we are processing your personal information, to access your personal information, and to request that we provide you a digital copy, if available, of your personal information that you previously provided to us.
• Right to correct. The right to request that we correct any inaccurate personal information we maintain about you.
• Right to deletion. The right to request that we delete certain personal information that we have collected from you, subject to our right to maintain your personal information for specific purposes permitted under applicable state law.
• Right to opt-out. The right to opt-out of sales of your personal information, the use of your personal information for targeted advertising, or the use of your personal information for “profiling” in furtherance of decisions that impact a legal or similar right. We do not engage in “profiling” to make decisions about consumers that impact legal or similar rights, so there is no need to opt-out.
• Right to appeal. The right to appeal a denial of a privacy rights-related request.