California residents may use this page to direct Menarlo not to sell or share their personal information, as those terms are defined by California law.

Sale and sharing

California law defines sale and sharing broadly. A transfer may qualify even where no money is exchanged.

Depending on the product, service and role of the relevant Menarlo entity, identifiers, internet activity, commercial information, approximate location and inferences may be made available to platforms, marketplaces, agencies, brands or technology partners in a manner that constitutes a sale or sharing under California law.

California residents have the right to direct us not to sell or share their personal information.

Menarlo also recognises qualifying browser-based opt-out preference signals, including Global Privacy Control, where required by law. Where technically feasible, our website will provide an indication that the signal has been recognised.

An opt-out applies to the browser, device or identifier through which the preference was communicated unless the request is associated with a verified account or additional identifiers.

Sensitive personal information

Where Menarlo processes sensitive personal information, we limit its collection, use, disclosure and retention to purposes that are reasonably necessary and proportionate, or provide the right to limit its use and disclosure where required.

[BUTTON — INCLUDE IF APPLICABLE: LIMIT THE USE OF MY SENSITIVE PERSONAL INFORMATION]

California consumer rights

Subject to applicable exceptions, California residents may have the right to:

• know the categories of personal information collected;
• know the categories of sources;
• know the purposes for collection, use, sale or sharing;
• know the categories of third parties to whom information is disclosed;
• access specific pieces of personal information;
• correct inaccurate personal information;
• delete personal information;
• opt out of sale or sharing;
• limit certain uses and disclosures of sensitive personal information;
• receive information in a portable format; and
• receive equal service and pricing without retaliation for exercising a privacy right.

How to exercise California rights

A request may be submitted using:

Privacy Request Form

Email: [INSERT PRIVACY EMAIL ADDRESS]

Telephone: [INSERT TOLL-FREE NUMBER IF REQUIRED]

We may need to verify the request. The information required for verification will depend on the request and the information involved.

Because many advertising products use pseudonymous identifiers, we may ask for information that enables us to locate the relevant record, such as:

• a cookie identifier;
• a mobile advertising identifier;
• a device or platform identifier;
• the email address used in an interaction;
• a hashed version of an identifier; or
• other information reasonably required to match the request.

We will use verification information only for handling the request, preventing fraud and maintaining the records required to demonstrate compliance.

An authorised agent may submit a request on behalf of a California resident. We may request proof of the agent’s authority and may contact the resident directly where permitted.

California data-broker requests

[INCLUDE THIS SECTION ONLY IF MENARLO OR THE RELEVANT GROUP COMPANY IS REGISTERED OR REQUIRED TO REGISTER AS A CALIFORNIA DATA BROKER]

California residents may use the California Delete Request and Opt-Out Platform, known as DROP, to submit a deletion request to registered data brokers.

Where the relevant Menarlo entity is registered and a request matches information held by that entity, the request will be processed in accordance with the California Delete Act and applicable regulations, subject to lawful exemptions.

Information for registered data brokers is available on the official DROP for data brokers page.

Browser-based opt-out signals

Where required by law, Menarlo recognises qualifying browser-based opt-out preference signals, including Global Privacy Control. The preference generally applies to the browser, device or identifier through which it is communicated unless it is linked to a verified account or additional identifiers.

Effective date: [INSERT DATE]

Last updated: [INSERT DATE]