California Privacy Policy

This policy was last modified on July 1, 2023.

This California Privacy Policy (this “California Privacy Policy”) supplements the information contained in the Privacy Policy of GMG with additional disclosures required by California law that apply only to residents of California. Any terms defined in the Privacy Policy or by California law in the California Consumer Privacy Act (“CCPA”) have the same meaning when used in this California Privacy Policy.

By using the Site, you agree to the practices described in this California Privacy Policy and any updates posted here from time to time. To make sure you stay informed of all changes, you should check this California Privacy Policy periodically. Updates will be referenced by the “Last Modified” date shown above.

Table of Contents

• 1. Definition of Personal Information
• 2. Notice of Collection of Personal Information
• 3. Personal Information Sold or Shared to Third Parties
• 4. Your California Consumer Privacy Rights
• 5. Exercising Your California Privacy Rights
• 6. California Consumer Privacy Rights Metrics
• 7. Contact Us

1. Definition of Personal Information

As defined in the CCPA, “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.

2. Notice of Collection of Personal Information

Categories of Personal Information Collected

We may collect and may have collected in the last 12 months the following categories of Personal Information:

Please note that the categories and examples listed above are those defined by California Law. This does not mean that all examples of that category of Personal Information were in fact collected about every Site visitor, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information would only be collected if you provided such Personal Information when applying for a job via the Site, but not if you submitted a general inquiry or just visited the Site.

We collect the categories of Personal Information listed above from the following categories of sources:

• Directly from you when you provide it to us.
• Indirectly and automatically from your devices. For example, when you visit or interact with the Site.
• Directly from our parents, affiliates, subsidiaries, and other companies under common control and ownership.
• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
• From vendors who provide services to us.
• From other third parties. For example, sponsors or event partners in connection with certain ticketed events, social networking providers, and advertising companies. If you do not want us to collect information from social networks, you should review and adjust your privacy settings on those networks as desired before linking or connecting them to the Site.

We collect the categories of Personal Information listed above for the following business and commercial purposes:

• Fulfill our obligations with respect to the reason you voluntarily provided the data (such as responding to an inquiry or provide you with information, products, or services that you request from us or that may be of interest to you);
• Allow you to participate in certain features of the Site;
• Improve the Site or our products, events, and services and for other business or commercial purposes;
• Optimize your experience on the Site (such as troubleshooting technical programs or storing your preferences);
• Provide co-branded services and features (such as contests, sweepstakes, or other promotions);
• Notify you about changes to the Site (including this Privacy Policy);
• Carry out any other purpose described to you at the time the data was collected; and
• Carry out any other purpose with your consent or as permitted by law.
• Provide you with additional information regarding products, events, promotions, and services from GMG and third-party advertisers via email or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit;
• Deliver relevant advertisements from GMG and third-party advertisers; and
• Develop, improve, and target our advertising and promotional messaging to you and others via retargeting, online behavioral advertising, and use of social media platform tools for advertising (such as creation of Facebook Lookalike Audiences).

Sensitive Personal Information

We will get your explicit consent for our collection, use, or sharing of Sensitive Personal Data as required by law. Please note that we only use Sensitive Personal Information for the purpose for which it was collected, and we do not use it to infer characteristics about you.

3. Personal Information Sold or Shared to Third Parties

We may sell or share and may have sold or shared in the last 12 months the following categories of Personal Information:

• Identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Protected classNameification characteristics under California or federal law.
• Commercial information.
• Online activity; Internet or other electronic network activity information.
• Geolocation data.
• Professional or employment-related information.
• Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
• IdentifiInferences drawn from any of the information.

As defined by California Law, “sale” and “share” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing Personal Information, but not necessarily a monetary benefit.

Please note that the categories listed above are those defined by California Law. This does not mean that all examples of that category of Personal Information were in fact sold or shared, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

In connection with the business and commercial purposes provided above, we may sell or share and may have sold or shared Personal Information, with the following third parties:

• With our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
• With our service providers that perform services for us (such as e-mail and mobile marketing, analytics, and web hosting);
• With our sponsors, promotional partners, or event partners in connection with certain contests, sweepstakes, promotions, or ticketed events;
• With our third-party vendors and partners that sell items, offer promotions, or provide services to you through our services (either alone or jointly with us), as well as third-party advertisers, agencies, networks, ad measurement providers, and other marketing and advertising providers and partners;
• To comply with a court order or other legal obligation, to enforce the Site terms of use, and to protect the rights, property, or safety of our users and other third parties;
• With government or law enforcement officials or private parties (including our legal or other professional advisors) as we determine, in our sole and absolute discretion, is necessary or appropriate to respond to claims or to comply with legal processes, laws, regulations, or ordinances, or to prevent or stop illegal, unethical, or actionable activity;
• In connection with, or during negotiations of, any merger, acquisition by another company, or sale of all or substantially all of our business or assets.

4. Your California Consumer Privacy Rights

The CCPA provides residents of California with the following rights regarding their Personal Information:

Right to Know About Personal Information Collected or Disclosed

You have the right to request, twice in a 12-month period, that we disclose certain information to you about our collection, use, and disclosure of your Personal Information over the last 12 months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you within the time required by the CCPA, the relevant information.

Right to Request Deletion of Personal Information

You have the right to request that we delete any of your Personal Information that we collected from you and retain, subject to certain exceptions. Once we receive and confirm a verifiable consumer request from you, we will delete (and direct our service providers to delete) your Personal Information from our records within the time required by the CCPA, unless an exception applies.

Right to Correct Personal Information

You have the right to request that we correct inaccurate Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable consumer request from you, we will correct (and direct our service providers to correct) your Personal Information in our records with the time required by the CCPA, unless an exception applies.

Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of your Personal Information. Once we receive and confirm a verifiable consumer request from you, we will stop selling or sharing your Personal Information. Please submit a request through our Do Not Sell web form.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive discriminatory treatment by us for the exercise of any your CCPA rights. We will not discriminate against you for exercising any of your CCPA rights.

California Consumers Under 16 Years of Age

We do not have actual knowledge that we sell or share personal information of consumers under 16 years of age.

5. Exercising Your California Privacy Rights

To exercise any of the rights described above, please submit a request by completing this form.

Verification of Requests

When you submit your request, we will reasonably verify your identity prior to processing your request to access or delete any Personal Information we may hold about you. You must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

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

Making a Request through an Authorized Agent

You may submit a request through an authorized agent. The agent will need to state that they are acting on your behalf when making the request, have proof of the authority to act on your behalf, and be prepared to provide sufficient Personal Information to enable us to identify you in our records.

6. California Consumer Privacy Rights Metrics

California law requires us to disclose metrics on the number of requests we have received from California consumers in the previous calendar year. This information is provided in the chart below.

Requests Submitted 1/1/22 – 12/31/22*

*The metrics above reflect requests received from all individuals, rather than requests received from California consumers only.

**Denied means that the request was not verifiable or was denied on other grounds.

7. Contact Us

To submit a request relating to Your California Privacy Rights, please complete this form. Please note that requests submitted through the form are processed more quickly than requests submitted by email or mail.

If you have any questions about this California Privacy Policy or would like more information about the third parties that may collect Personal Information about you and how you may reach those third parties to exercise any rights available to you under applicable law, please email us at privacy@gallerymediagroup.com or write to us at:

VaynerStudios, LLC (d/b/a Gallery Media Group)Attention: Legal Department; Privacy Policy Inquiry10 Hudson Yards, 25th FloorNew York, NY 10001