CALIFORNIA PRIVACY NOTICE
Last Updated: May 11, 2025
This California Privacy Notice (“Notice”) supplements the information contained in the Privacy Policy of ReservePath, owned and operated by VRLY Ventures LLC (“we,” “us,” or “our”), and applies solely to residents of the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (“CCPA/CPRA”). Any terms defined in the CCPA/CPRA have the same meaning when used in this Notice.
1. INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).
In the past 12 months, we have collected the following categories of personal information from consumers:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, email address, phone number, mailing address, unique personal identifier, online identifier, Internet Protocol address, account name | YES |
| B. Personal information categories listed in the California Customer Records statute | Name, address, telephone number, education, employment, employment history, financial information | YES |
| C. Protected classification characteristics under California or federal law | Age (40 years or older), race, color, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender) | NO |
| D. Commercial information | Records of products or services purchased, obtained, or considered, purchasing or consuming histories or tendencies | YES |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, activity patterns used to extract a template or other identifier, fingerprints, faceprints, voiceprints, iris or retina scans | NO |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement | YES |
| G. Geolocation data | Physical location or movements | YES |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations | YES |
| J. Non-public education information | Education records directly related to a student maintained by an educational institution | NO |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | YES |
| L. Sensitive personal information | Government identifiers, financial account information, precise geolocation, contents of mail/email/text messages, genetic data, biometric information, health information, information about sex life or sexual orientation | LIMITED |
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you (e.g., forms you complete, products and services you purchase, or customer service interactions)
- Indirectly from you (e.g., from observing your actions on our website or from information your computer or device provides when you visit our websites)
- From service providers (e.g., payment processors, marketing partners, or data analytics providers)
2. USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To provide, support, personalize, and develop our website, products, and services
- To process your requests, purchases, transactions, and payments
- To provide customer service and respond to inquiries
- To personalize your experience and deliver content relevant to your interests
- To improve our website, products, and services
- To conduct research and analysis related to our business activities
- To maintain the safety, security, and integrity of our website, products and services, databases, other technology assets, and business
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
- For any other purpose described to you when collecting your personal information
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to third parties for business purposes. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for business purposes:
- Category A: Identifiers
- Category B: California Customer Records personal information categories
- Category D: Commercial information
- Category F: Internet or other similar network activity
- Category G: Geolocation data
- Category I: Professional or employment-related information
- Category K: Inferences drawn from other personal information
4. DATA PRACTICES REGARDING PERSONAL INFORMATION
In the preceding twelve (12) months, we have engaged in the following business practices:
A. Information Disclosure
We have disclosed certain categories of personal information to third parties for business purposes. The categories of third parties to whom we disclosed personal information include:
- Cloud service providers
- Payment processors
- Customer relationship management services
- Analytics providers
- Marketing and advertising partners
- Professional service providers (legal, accounting, etc.)
B. Information Handling
We do not sell personal information as the term “sell” is commonly understood. However, under the CCPA/CPRA, sharing certain types of information in certain contexts, including allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior to provide advertising on our Services or other sites, may be considered a “sale” of personal information.
We do not “share” personal information as defined under the CCPA/CPRA for purposes of cross-context behavioral advertising.
We do not use or disclose sensitive personal information for purposes other than those specified in the CCPA/CPRA.
We have no actual knowledge of selling or sharing personal information of consumers under 16 years of age.
5. YOUR RIGHTS UNDER THE CCPA/CPRA
The CCPA/CPRA provides California residents with specific rights regarding their personal information. This section describes those rights and explains how to exercise them.
A. Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected about you
- Our business or commercial purpose for collecting, selling, or sharing personal information
- The categories of third parties with whom we share personal information
- The specific pieces of personal information we collected about you
- If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained
B. Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
C. Right to Correct
You have the right to request correction of inaccurate personal information that we maintain about you. Upon receiving a verifiable request, we will use commercially reasonable efforts to correct the inaccurate personal information as directed, taking into account the nature of the personal information and the purposes of the processing of the personal information.
D. Right to Limit Use and Disclosure of Sensitive Personal Information
Where applicable, you have the right to limit the use or disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer.
E. Right to Opt-Out of Sale or Sharing of Personal Information
If we engage in practices that may be considered “selling” or “sharing” of your personal information under the CCPA/CPRA, you have the right to opt-out of such practices.
F. Right to Non-Discrimination
We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not:
- Deny you goods or services
- Charge you different prices or rates for goods or services
- Provide you a different level or quality of goods or services
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
6. EXERCISING YOUR CALIFORNIA PRIVACY RIGHTS
A. Submitting Requests
To exercise the rights described above, please submit a verifiable consumer request to us by:
- Emailing us at privacy@reservepath.com
- Visiting https://reservepath.com/privacy-center
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
B. Verification Process
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 verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
C. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. If applicable, our response will also explain the reasons we cannot comply with a request.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer 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.
7. NOTICE OF FINANCIAL INCENTIVE
We currently do not offer any financial incentives or price or service differences in exchange for the retention or sale of personal information.
8. CHANGES TO THIS CALIFORNIA PRIVACY NOTICE
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
9. CONTACT INFORMATION
If you have any questions or comments about this Notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:
Website: https://reservepath.com/privacy-center
Email: privacy@reservepath.com
Postal Address:
VRLY Ventures LLC
Attn: Privacy Officer
1346 How Lane, Unit 7
North Brunswick Township, NJ 08901