US Multistate Privacy Addendum

Privacy Notice for Residents of Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia

Last Updated: May 15, 2025. ‎

This Privacy Notice applies to Touch Point Worldwide Inc. or one of our affiliates, (“TPW,” “we,” “us,” or “our”)‎ processing of information that is linked or reasonably linkable to an identified or identifiable natural person (“Personal Data”) who is resident in one of the following states, to the extent the following laws apply:

Colorado – the Colorado Privacy Act

Connecticut – the Connecticut Data Privacy Act

Delaware, the Delaware Personal Data Privacy Act

Iowa – the Iowa Consumer Data Protection Act

Montana – the Montana Consumer Data Privacy Act

Nebraska – the Nebraska Data Privacy Act

New Hampshire – New Hampshire SB 255

New Jersey – New Jersey SB 332

Oregon – the Oregon Consumer Privacy Act

Texas – the Texas Data Privacy and Security Act

Utah – the Utah Consumer Privacy Act

Virginia – the Virginia Consumer Data Protection Act 

 

This Privacy Notice does not apply to Personal Data collected pursuant to various exemptions including for (i) information related to an individual acting in a commercial or employment context, and (ii) de-identified or publicly available information. 

How we process Personal Data

Please review the below chart for information about the categories of Personal Data we process; the purpose for processing Personal Data; the categories of Personal Data that we share with third parties, if any; and the categories of third parties, if any, with whom we share Personal Data. 

How we process Personal Data

Please review the below chart for information about the categories of Personal Data we process; the purpose for processing Personal Data; the categories of Personal Data that we share with third parties, if any; and the categories of third parties, if any, with whom we share Personal Data.

Category of Personal Information Examples of Personal Information Collected or Used Expected Retention Period or Criteria for Retention Is the Category of Personal Information Shared? Business or Commercial Purpose(s) for Which Used or Collected
Identifiers Contact details, such as user name, real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name. Personal Information is retained based on internal retention policies. Information is segregated by legal retention requirements and maintained in accordance with various local, state, federal, and other legal requirements. Personal Information will not be retained beyond the reasonably foreseen need to retain the information for legal or business purposes. We do not share personal information for the purpose of cross-context behavioral advertising.
  • For human resources purposes.
  • To process, service, and enforce transactions with you or entities affiliated with you.
  • To present our website and contents to you.
  • To notify you about changes to our website, policies, products or services.
  • To support, change, improve, and develop our products and services.
  • For research, analysis, modeling, marketing, or advertising purposes.
  • Fraud detection and prevention.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To protect the rights, property, or safety of ourselves, our partners and others.
  • To compile statistics for analysis.
  • To help maintain the safety, security, and integrity of our systems, services, databases and other assets.
Personal Information Categories Listed in the California Customer Records statue (Cal. Civ. Code 1798.80(e)) Name, contact information, government identifiers such as a social security number from our personnel, education, employment, employment history and financial information.
Characteristics of protected class classifications under California or federal law Demographic information, such as age and gender.
Commercial Information Transaction information, purchase history, financial details such as direct deposit information for our personnel, and payment information.
Biometric Information We do not collect this category of personal information.
Internet or other electronic network activity information Basic telemetry data related to interactions with our websites, applications, company email and file shares, systems and advertisements. Personal Information is retained based on internal retention policies. Information is segregated by legal retention requirements and maintained in accordance with various local, state, federal, and other legal requirements. Personal Information will not be retained beyond the reasonably foreseen need to retain the information for legal or business purposes. We do not share personal information for the purpose of cross-context behavioral advertising.
  • To inform you of and provide services and products to you that you request from us.
  • For human resources purposes.
  • To process, service, and enforce transactions with you or entities affiliated with you.
  • To present our website and contents to you.
  • To notify you about changes to our website, policies, products or services.
  • To support, change, improve, and develop our products and services.
  • For research, analysis, modeling, marketing, or advertising purposes.
  • Fraud detection and prevention.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To protect the rights, property, or safety of ourselves, our partners and others.
  • To compile statistics for analysis.
  • To help maintain the safety, security, and integrity of our systems, services, databases and other assets.
Geolocation data Approximate device location.
Sensory Data Images and audio, video or call recordings created in connection with our business activities. Personnel may participate in and help create promotional media content.
Professional or employment-related information Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply to work with us.
  • For human resources and hiring purposes related to working at or applying to work with us.
  • To protect the rights, property, or safety of ourselves, our partners and others.
Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. 1232g, 34 C.F.R. Part 99)) We do not collect this category of personal information.
Inferences drawn from other personal information We do not collect this category of personal information.
Sensitive Personal Information A Social Security number or other government identifier; account login information or a financial account number; contents of company mail, email, or text messages. Personal Information is retained based on internal retention policies. Information is segregated by legal retention requirements and maintained in accordance with various local, state, federal, and other legal requirements. Personal Information will not be retained beyond the reasonably foreseen need to retain the information for legal or business purposes. We do not share personal information for the purpose of cross-context behavioral advertising.
  • Our affiliates and agents.
  • Third party service providers who perform business, professional, or other functions for us.
  • Our partners when we act as their service provider and process the collected data on their behalf.
  • Governments as required by law.

We may sell your Personal Data. As described below, you may have the right to opt-out of the sale of your Personal Data. We may disclose certain cookies information about you with our third party service providers who assist us with website operations.  To learn more about our online collection of information, or to modify your cookies settings, please review our online privacy policy here.

 

Your Privacy Rights

Submitting Consumer Requests

You may submit a consumer request to us by email to support@berify.io‎ ‎to make a consumer request.

Only you, or someone legally authorized to act on your behalf, may make a consumer request related to your Personal Data. You may also make a consumer request on behalf of your minor child.

Making a consumer request does not require you to create an account with us.

When you submit a consumer request, we will take steps to verify your request ‎by email or telephone call.  In some cases, we may request additional information in order to verify ‎your request or where necessary to process your request. If we are unable to adequately verify a ‎request, we will notify the requestor.  Authorized agents will be required to provide proof of their ‎authorization and we may also require that the relevant consumer directly verify their identity and ‎the authority of the authorized agent.‎

We will only use Personal Data provided in a consumer request to verify the requestor’s identity or authority to make the request.

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

Right to Appeal

You may have the right to appeal our responses to your consumer requests.  If you believe you have a basis for such an appeal, please contact us by email to support@berify.io ‎to make an appeal request and provide any required information to submit your appeal.  If you wish to file a complaint related to your appeal, please visit the website of your state’s data privacy regulator. We have listed the contact pages that are readily available here:

Colorado: https://coag.gov/file-complaint/
Connecticut: https://portal.ct.gov/ag/common/complaint-form-landing-page
Oregon: https://www.doj.state.or.us/consumer-protection/contact-us/
Texas: https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint
Virginia: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint

Right to Know and Access

You have the right to request that we confirm whether or not we are processing your Personal Data and to request access to that Personal Data.  To submit a request, please review the section above titled, “Submitting Consumer Requests.” 

Right to Obtain a Copy of Personal Data

You have the right to obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller, where the processing is carried out by automated means.  To submit a request please review the section above titled, “Submitting Consumer Requests.” 

Right to Request Deletion

You have the right to request that we delete Personal Data about you that we process.  To submit a request, please review the section above titled, “Submitting Consumer Requests.” 

You should be aware, however, that we are allowed to retain your Personal Data under certain conditions, even if you have asked us to delete it, such as when retaining your Personal Data is necessary for us to complete a transaction with you or provide you with a good or service you have requested.  We will notify you of any denial of your deletion request and the reason for such denial.

Right to Request Correction

You may have the right to request that we correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.  To submit a request, please review the section above titled, “Submitting Consumer Requests.” 

Right to opt out of certain processing

Consumers have the right to opt out of certain categories of processing of Personal Data.  These include the right to opt out for purposes of (i) targeted advertising, (ii) the sale of Personal Data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.  To submit a request to opt-out, please review the section above titled, “Submitting Consumer Requests.”

Contact for Additional Information

If you have questions about this policy, please contact us at:

Email: support@berify.io.‎

Post:‎ Touch Point Worldwide, Inc., 145 Columbine Ave., Santa Ana, CA 92707‎

 

 

 

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