This Multi-State Privacy Rights Notice (“Notice”) describes the rights available to residents of states with comprehensive consumer privacy laws and explains how to exercise them in connection with the Surely Services. This Notice supplements the Surely Privacy Policy and applies in addition to, not in place of, that Policy.
1. Rights You May Have
Depending on your state of residence, you may have some or all of the following rights with respect to your personal information:
- Right to Know / Access — confirm whether we process your personal information and obtain a copy or description of it.
- Right to Delete — request deletion of personal information we have collected about you, subject to legal exceptions.
- Right to Correct — request correction of inaccurate personal information.
- Right to Portability — receive a copy of your personal information in a portable, and where technically feasible, readily usable format.
- Right to Opt Out — opt out of the sale of personal information, sharing for cross-context behavioral advertising, or profiling that produces legal or similarly significant effects. As described in Your Privacy Choices, Surely does not engage in any of these practices, so this right has no practical effect today, but we will honor it if that changes.
- Right to Limit Use of Sensitive Personal Information — request that we limit our use of sensitive personal information (such as the contents of the communications, documents, and files you connect or store) to what is reasonably necessary to provide the Services.
- Right to Non-Discrimination — we will not deny goods or services, charge different prices, or provide a different level of quality because you exercised a privacy right.
- Right to Appeal — if we decline to act on your request, you may appeal the decision as described in Section 4 below.
- Right to Use an Authorized Agent — you may designate an authorized agent to submit a request on your behalf, subject to our ability to verify the agent’s authority and your identity.
Not every right is available in every state, and some states impose different conditions or exceptions. We apply the rights above consistently to all users regardless of state of residence as a matter of practice, except where doing so would conflict with applicable law.
2. States With Applicable Comprehensive Privacy Laws
As of the effective date of this Notice, comprehensive consumer privacy laws granting rights of this kind are in effect in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, with additional states’ laws taking effect on a rolling basis. If you are unsure whether your state’s law applies to you, submit a request as described below and we will evaluate it.
3. How to Submit a Request
You may submit a request to exercise any right described in this Notice by:
- Emailing privacy@surelynetworks.com with the subject line “Privacy Rights Request”; or
- Writing to Surely Networks, LLC, 2810 N Church St, PMB 548750, Wilmington, Delaware 19802-4447.
We will take reasonable steps to verify your identity before completing a request to know, delete, correct, or port your information, which may include confirming information already associated with your account. We will respond within the time required by the law applicable to you (generally 45 days, which may be extended once by an additional 45 days with notice to you).
4. How to Appeal
If we decline to act on your request, in whole or in part, we will explain why. You may appeal that decision by replying to our response, or by emailing privacy@surelynetworks.com with the subject line “Privacy Rights Appeal,” within a reasonable time after our decision. A different, appropriately qualified person than the one who made the initial decision will review your appeal. We will respond to your appeal within the time required by applicable law (generally 45 to 60 days, depending on your state). If we deny your appeal, we will provide you with a method to submit a complaint to your state Attorney General or other applicable privacy regulator.
5. Authorized Agents
If you use an authorized agent to submit a request on your behalf, we may require the agent to provide proof that you have authorized them to act on your behalf, and we may still require you to verify your own identity directly with us or confirm the request personally, as permitted by applicable law.
6. No Retaliation
We will not discriminate or retaliate against you for exercising any right described in this Notice, including by denying goods or services, charging different prices, or providing a different level or quality of the Services.
7. Changes to This Notice
We may update this Notice from time to time as state privacy laws evolve. The most current version will always be available through the Services.
8. Contact
Questions about this Notice can be sent to privacy@surelynetworks.com or to Surely Networks, LLC, 2810 N Church St, PMB 548750, Wilmington, Delaware 19802-4447.