EPITAPH RECORDS
GDPR - CCPA Privacy policy


EFFECTIVE DATE: This Privacy Policy is effective as of September 01, 2022

This website is operated by Epitaph, a California corporation, headquartered in Los Angeles, who is responsible for the processing of your Personal Data, and who operates the following record labels: Epitaph Europe BV, ANTI-, Hellcat Records LLC, Burning Heart Records, and Heartcore Music and Clothing AB (BHR).

"Epitaph" includes all entities Epitaph controls, is controlled by or is under common control with, including subsidiaries, joint ventures, or other entities in whom Epitaph has a substantial ownership interest.

While you use our website, we are processing your Personal Information (or “Personal Data”). You have the right to know what we do with it and the choices you have over your Personal Information.

This Privacy Policy (or "Policy") is addressed to all of the individuals whose Personal Information we are processing.

In this Privacy Policy:

  • When we say “we”, “us” and “our”, we are referring to Epitaph Records, a California Corp.Epitaph, a California corporation, which is the “Controller” under the GDPR, and a “Business” under the CCPA;

  • When we say “you”, “user” or “individual(s)”, we are referring to the person accessing and using our website, and the person whose Personal Information we are collecting, using and disclosing;

  • When we say “processing”, we are referring to the collection, use or disclosure of your Personal Information;

  • When we say “processor” of your Personal Information, we are referring to organizations that process your Personal Information on our behalf (“service providers” under the CCPA).

“Personal data” or “Personal information” is any data that can be used to identify you directly or indirectly (e.g., your identity data, bank statements, device identifier, location, your political opinion, biometric data, credit card details, browsing activity, IP address).

If you have any questions or concerns about this Policy, please feel free to contact us at privacy@epitaph.com or at:

Epitaph Records
ATTN: Privacy Request
2798 Sunset Bvld.
Los Angeles, CA 90026
United States 

If you are an EU resident, you may also contact our EU representative at:

Osano International Compliance Services Limited
ATTN: 3ZVC
25/28 North Wall Quay
Dublin 1, D01 H104
Ireland

Or our EU office at:

Epitaph Europe BV
Antennestraat 6
1322 AB  Almere
The Netherlands
VAT ID: NL001312182B01

TABLE OF CONTENTS

  1. WHAT PERSONAL DATA WE COLLECT FROM YOU AND HOW WE COLLECT IT

  2. FOR WHAT PURPOSES WE USE YOUR PERSONAL DATA

  3. TO WHOM WE DISCLOSE YOUR PERSONAL DATA

  4. HOW LONG WE STORE YOUR PERSONAL DATA

  5. HOW WE DEAL WITH CHILDREN’S PRIVACY

  6. HOW WE SAFEGUARD YOUR PERSONAL INFORMATION

  7. YOUR RIGHTS ON YOUR PERSONAL DATA

  8. IF WE MAKE CHANGES TO THIS PRIVACY POLICY

  9. ADDITIONAL PRIVACY STATEMENT FOR EU RESIDENTS (GDPR)

  10. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS (CCPA)

1 – WHAT PERSONAL DATA WE COLLECT FROM YOU AND HOW WE COLLECT IT

We collect your Personal Information under the following circumstances:

  • You provide it to us directly;

  • We collect it from external sources; or

  • We collect it by using automated means.

1.1 – The Personal Data we collect directly from you

In short: During our interactions with you, you may be asked to provide us with information that relates to you. For example, we collect this Personal Information when you participate in our contests or subscribe to our newsletter. The Personal Information we collect may vary whether you purchase products and services from us or if you are a member or a user of our website.

In detail: The Personal Data that you provide to us directly are the following:

  • Identifiers and profile information, (i.e., name, email, phone number, birthdate, Meta/Twitter/Tiktok/Spotify/Apple Music/Deezer usernames);

  • Demographic information (i.e., postal address, country of residence, telephone number);

  • Engagement information (i.e., information on products and services that you purchase, or the promotional offers that you participate in, information relating to your purchase history and your commercial relationship with us).

  • User Content (i.e., content of communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our website).

You will find further details in the summary table below.

1.2 – THE DATA WE COLLECT FROM EXTERNAL SOURCES

In short: We also collect Personal Information about you from external sources from our business partners, analytics providers, and affiliates.

In detail: We collect Personal Information about you from third-party organizations, including our e-commerce merchandising partners (that sell products to you on our stores or on our artists’ stores), artists that we sign (who may disclose their customer and subscriber lists to us), or other 3rd party eCommerce stores.  

Before we collect Personal Information from third-party organizations, we ensure that they have properly informed you of the transmission and the purpose of the transmission of your Personal Information to us.

1.3 – THE DATA WE COLLECT AUTOMATICALLY

In short: During each of your visits to our sites and mobile applications, we collect automatically information about your connection and your browsing activity.

In detail: We use different technologies to collect your Personal Data, for example through cookies. To find out more about what a cookie is and how we use it, you can refer to our cookie policy.

2 – FOR WHAT PURPOSES WE USE YOUR PERSONAL DATA

In short: We collect Personal Information for specific purposes, and we limit the processing of your Personal Information to what is necessary. Unless required by law or for exceptions set out in applicable legislation, we will not process your Personal Information for a purpose that was not previously identified without informing you, and without collecting your prior consent when we are required to do so.

In detail: We process your Personal Data for the following purposes:

  • Business purposes:

    • Auditing our interactions with you (counting ad impressions to unique visitors, verifying positioning and quality of ad impressions); and

    • Performing our services (either by us or by our service provider, e.g., maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payment).

  • Commercial purposes:

    • Advancing our commercial or economic interests, such as inducing you to buy, join, or subscribe to our services;

    • Setting up of contests or other promotional operations;

    • Setting up of contests or other promotional or event operations with our business partners;

    • Sharing and exchanging Personal Information with business partners so that they may contact you with offers they think might be of interest to you.

If you are an EU resident, you can find in the GDPR section of our privacy policy detailed information on the purposes and on the legal grounds on which we process your Personal Information.

3 – TO WHOM WE DISCLOSE YOUR DATA

In short: In certain circumstances, we disclose your Personal Data to external organizations (e.g., our service providers, or social media platforms, our business partners…) or public authorities. For additional information on the categories of Personal Information we disclose or sell to third parties, please see the CCPA section of our privacy policy.

In detail: In the preceding twelve (12) months, we have shared, and we continue sharing your Personal Data to the following categories of third parties:

  • Our service providers/processors (such as ISPs, operating systems and platforms)

    • Our service providers have access to your Personal Information for the following business purposes: managing your subscription, collecting customer reviews, for securing your online transactions, for fraud detection, for managing phone calls...

    • Your information will be treated with the same level of privacy and security as we are committed to providing and will not be used for other purposes than that which we authorize. The disclosure of your Personal Data to our processor is made on the basis of signed contracts that are binding and that mention their obligations in terms of data protection, data security and confidentiality.

  • Our business partners and publishing partners

    • The following categories of business partners may receive your Personal Information for marketing and commercial purposes: advertising networks, data analytics providers, social networks, band merchandising companies, and web stores.

    • The purposes of such disclosure are commercial purposes are the following: sending you advertising and marketing messages, analytics and improvement and optimization of our website, and tailoring the advertisements that are displayed on social media.

    • When we are required by law, we will always collect your consent before disclosing your Personal Information to our business partners and publishing partners. For example, as required by GDPR and the e-Privacy directive, you will be provided with a list of these commercial partners if we rely on your consent for such disclosure.

    • If you decide to subscribe to the products or services of our business partners and you allow them to access some of your information, in particular by logging into their sites or applications, their privacy policies will be applicable to you. We have no control over the collection, use and disclosure of your information when carried out by our business partners on their own website.     

  • Links to third-party content

    • Our website may include or link to third-party websites, applications, or platforms. For example, we may permit you to connect with us on Meta, Twitter, TikTok, YouTube, Spotify, and Apple Music. If you connect with us on these third-party social networks, we will receive information that you have permitted through your settings on those accounts. For example, if you log in to our site using your Facebook account and choose to allow Facebook to share your profile with us, we may collect that information. Please review your privacy settings on those accounts to control what information is provided to us through this option.

    • Similarly, if you post information on a third-party service that references Epitaph (for example, by mentioning us in a tweet or status update), your post may be used by us.

  • Public authorities, judicial or administrative authorities

    • We may disclose your Personal Information when we are required or authorized by law to cooperate with local, national or international law enforcement or other authorities for the reporting of and/or investigation of improper or unlawful activities, or if we need to comply with court orders.

  • Third-parties in the event of a sale or business transaction

    • We may share your Personal Information in connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity.

4 – HOW LONG WE STORE YOUR PERSONAL DATA

In short: We will not retain your Personal Data indefinitely. Our retention periods vary depending on whether we have an ongoing contractual relationship (you are an active customer), whether we have had a contractual relationship with you in the past (you are an inactive customer), or whether we never have had such a relationship with you (you are a prospective customer).

In detail: When their retention is no longer justified by legal, commercial or customer account management requirements, or if you have made use of a right of modification or erasure, we will delete your Personal Data securely. The criteria we use to determine our retention periods include:

  • The length of time we have an ongoing relationship with you;

  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them); and

  • Any guidelines issued by relevant regulators.

5 – HOW WE DEAL WITH CHILDREN’S PRIVACY

In short: We do not provide services directly to children and proactively collect their Personal Information.

In detail: We do not knowingly collect personally identifiable information from anyone under the age of 13.

If we ever decide otherwise, we will update this Privacy Policy to adapt it specifically to children and put into place an age verification process. We will also seek parental consent when applicable legislation requires us to do so.

If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us.

6 – HOW WE SAFEGUARD YOUR PERSONAL INFORMATION 

In short: Your Personal Information is important to us, and we take all useful precautions, with regards to the risks created by the processing that we carry out, to preserve the security of your Personal Information and, to prevent their alteration and damage, or any access by non-authorized third parties. These safeguards include physical, organizational and technical measures.

In detail: As we are responsible for your Personal Information, we implement appropriate technical and organizational measures in accordance with applicable legal provisions, to protect your Personal Information against alteration, accidental or unlawful loss, use, disclosure or unauthorized access. Safeguards include physical, organizational and technical measures including but not limited to:

  • The creation of a unit dedicated to the security of information systems;

  • Raising awareness of the confidentiality requirements of our employees who have access to your Personal Information;

  • Securing access to our premises and to our IT platforms;

  • The implementation of a general IT security policy for the company;

  • Firewalls, anti-virus, strong passwords and software solutions for technical security

7 – YOUR RIGHTS ON YOUR PERSONAL DATA

Your rights with respect to your Personal Information depend on the data protection laws applicable to you as a resident of a country, state, or territory. General rights that may apply to you include the right to:

  • access your Personal Information;

  • rectify inaccurate Personal Information;

  • erase some or all of the Personal Information related to you;

  • receive a copy of your Personal Information in a structured, commonly used format or have us transmit it to another business/controller; and to

  • withdraw your consent.

If you are a California resident, your rights and information on how to exercise them are outlined here: ADDITIONAL PRIVACY STATEMENT FOR EU RESIDENTS (GDPR)

If you are a resident of the EU, your rights and information on how to exercise them are outlined here: ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS (CCPA)

If you would like to exercise your rights in relation to your Personal Information, you may contact us at privacy@epitaph.com or by filling out this form. When contacting us, please clarify what actions you would like us to take concerning your Personal Information and any specifics on the Personal Information your request relates to, so that we may deal with your request more efficiently.

8 – IF WE MAKE CHANGES TO THIS PRIVACY POLICY

In short: We may update this Policy to reflect changes to our information practices, but we will not reduce your rights under this Privacy Policy without your express consent. The review of our Privacy Policy will take place at least every 12 months. 

In detail: We will post any changes to this page and, if the changes are significant, we will provide a more prominent notice. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices and to contact us if you have any questions or concerns.

If you have any questions or concerns about this Policy, please feel free to contact us at privacy@epitaph.com or at:

Epitaph Records
ATTN: Privacy Request
2798 Sunset Bvld.
Los Angeles, CA 90026
United States 

If you are an EU resident, you may also contact our EU representative at:

Osano International Compliance Services Limited
ATTN: 3ZVC
25/28 North Wall Quay
Dublin 1, D01 H104
Ireland

9 – ADDITIONAL PRIVACY STATEMENT FOR EU RESIDENTS (GDPR)

The content below is intended only to apply to visitors, users, and others who reside in the European Union, and is adopted to comply with the standards enforced by the General Data Protection Regulation (“GDPR”). It is construed as a supplement to and not a replacement for our complete Privacy Policy.

9.1 – On what legal basis (i.e., for what reason) do we collect your Personal Data

In short: We must have a valid reason to use your Personal Data. One of the reasons we need to collect your Personal Data is that it is necessary for us to perform our contract with you. Another reason is the fact that we have a legitimate interest that justify the processing, or that we have a legal obligation to process the data. In all other cases, we will process your Personal Data because we have your consent.

In detail:

  • For some processing activities, we require your prior consent

    • You will always be prompted to take a clear, affirmative action so that we can ensure that you agree with the processing of your Personal Data. This action may, for example, take the form ticking a checkbox or clicking on a link.

    • Before obtaining your consent, we will systematically inform you of the purposes of the processing, and you can choose to consent to certain uses that we will make of your data and to refuse others.

    • If you have given us your consent, you may always change your mind, and withdraw your consent at any time and easily; all you need to do is to send us an email at the following address privacy@epitaph.com or click on the "unsubscribe link" at the bottom of our marketing e-mail communications. If you refuse to give us your consent, or decide to withdraw it, you will not suffer any negative consequences and will be able to continue to use the rest of our service. However, some functionality or features may be limited.

    • For example, we will ask for your consent before sending any electronic commercial communications to you. Your consent is also expressly requested to receive offers from our partner Kings Road Merch.

    • If you have given us your consent, and the processing we carry out on your Personal Data changes significantly, we will collect your consent again.

  •  When we justify our processing operations on the basis of a contract that we have with you

    • Certain processing of your Personal Data is necessary so that we can perform the service you have asked us to perform. For example, if you would like us to deliver a product to you, your address will be necessary for us to perform the contract.

    • We also use this justification if you ask us to take certain actions even before we enter into a contract with you (for example, you want to know if our services are available in your country of residence).

    • We justify our processing on our contract with you to process all the Personal Data that is necessary to ship your products or to respond to any queries you may have.

  • Processing operations that are necessary to meet our legal obligations

    • Like many organizations, we are subject to a number of regulations which require us to collect data about you. We will only collect the data that is necessary to meet our legal obligations.

  • Processing operations that are necessary to meet our legitimate interests

    • Legitimate interest is a set of commercial or business reasons that justify that we process Personal Data about you.

    • Our legitimate interests are the following to ensure the security of our systems, ensure the viability of our economic model, fraud detection.

    • We will use legitimate interest only when we have carried out an assessment on the impact that this processing may have on you and concluded that the processing does not unduly infringe your rights and freedoms. For example, we do not use this justification if we process sensitive data, or when the processing would be unexpected for you, or if we consider it to be too intrusive.

    • Please see our Cookies Policy for information on what Cookies (and other similar technologies) are and how we use them.

SUMMARY TABLE OF THE PERSONAL DATA WE MAY COLLECT, THE LEGAL BASIS, AND THE PURPOSES FOR COLLECTION

DATA COLLECTEDBASISPURPOSE FOR COLLECTION
ONLINE ACCOUNT MANAGEMENT AND PURCHASES
Names, first names, civility, date of birth, encrypted password, and marketing preferences.Contract• To register your account and to provide secured access to your account.
• To send you administrative information, such as information on our services and changes to our terms, conditions and policies.
• To allow you to send messages (for example, music clips or artist information) to a friend through our website. By using such functionality, you need to provide us with your friend's name and email address.
Name, telephone number, order details, shipping address and delivery preferences (when you purchase from our business partners).Contract• To complete and fulfil your purchases from our third-party partners, including sending you an order confirmation, sending you updates on your order and having your order delivered to you.
Name, email address, and details of your enquiry or query.Contract• To provide you with customer service, accessible by mail, telephone, e-mail or instant messaging such as chat, for any question or complaint.
MARKETING CAMPAIGNS AND DIRECT MARKETING
Name, gender, telephone number, email address, date of birth, post code, country, city, details of the competition or sweepstake you have participated in and your entry.

(Please see our cookie policy for information on marketing campaigns and direct marketing that we perform using tracking technologies).		Consent• To allow you to participate in our competitions, sweepstakes or similar promotions, and to administer these activities.
• If you use your social media account (e.g., Facebook, Twitter, TikTok…) or any other third-party user account to enter our competition, sweepstakes or promotions, you will share certain Personal Information from your third-party account with us.
Listening behavior on our partners’ platforms: information on tracks, playlists and albums listened to on streaming platforms you use, along with your top genres and artists.Consent• To analyze your listening behaviour for the purposes of determining what marketing content may be more suitable to send to you, if you have consented (on the streaming platform) to receiving direct marketing communications from us and in line with your marketing preferences.
• To monitor the performance of our content on streaming platforms by analysing users’ listening behaviour
Information on the pre-save/pre-added content you have selected, along with your name, email address, city, country and (if applicable) your marketing preferences where you have opted into receiving marketing communications from us.Consent• To add requested content to your streaming platform library when this content is officially released and to send you an email informing you of its official release.
• To send you marketing communications by email where you have agreed to receive these communications.
GENERAL INQUIRIES
Name, contact information and details of your communicationLegitimate Interests• To manage and to respond to your inquiries and fulfil your requests, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our website.
• To take into account your inquiries to improve our website, products and services
Name, contact information and your survey responses Consent• To register you for our surveys and to analyse the responses you have provided to our survey questions.
• To take into account your inquiries to improve our website, products and services.
Name, date of birth, gender, email address and post codeConsent• If you have an account with a digital service provider (e.g., Spotify) and agree to receive marketing communications from their partners through using their online tools, your digital service provider shares your Personal Information with us so that we send you marketing communications.
INTERNAL BUSINESS PROCESSES
Aggregated Information (Details of the competition or sweepstake you have participated in details of your communication survey responses, marketing preferences, social media username, name, date of birth, gender, email address and post code)Legitimate Interests• To develop new products and services;
• To enhance, improve, or modify our current products and services;
• To verify that our internal processes function as intended;
• To carry out fraud and security monitoring within our business, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
Aggregated Information (Details of the competition or sweepstake you have participated in details of your communication survey responses, marketing preferences, social media username, name, date of birth, gender, email address and post code)Legal Obligation• To verify that our internal processes are compliant with legal and regulatory requirements;
• To defend or bring claims to protect our legal rights and interests, and to respond to investigations from regulators or public authorities.

9.2 – YOUR RIGHTS UNDER THE GDPR

9.2-1 – Your general rights under the GDPR

In short: You have the right to ask us what data we process about you, and ask us to correct it, erase it, restrict it, and ask us to transfer your Personal Data to another controller in certain circumstances at the following address privacy@epitaph.com or by using our Data Subject Request Form.

In detail: You have the right to access your Personal Data and request that it be rectified, supplemented or updated. You can also request the erasure of your data, to restrict our processing, or object to our processing, provided you can justify a legitimate reason.

You can ask to exercise your right to the portability of your data, that is to say the right to receive the Personal Data that you have provided to us in a structured, commonly used format and the right to transmit this data to another data controller. This right only applies to Personal Information you have provided to us yourself (not any other information), that we process based on your consent or for the performance of a contract with you.

You can exercise your rights by contacting us at privacy@epitaph.com or by using our Data Subject Request Form.

Before responding to your request, we will verify your identity and / or ask you to provide us with more information to respond to your request, if we have any doubts about your identity. We will do our best to respond to your request within one month, unless your request is particularly complex (for example if your request concerns a large amount of sensitive data).  In such a case, we will inform you of the need to extend this response time by two additional months.

9.2-2 – Your RIGHTS TO OBJECT TO COMMERCIAL COMMUNICATIONS

In short: When we use your Personal Information to contact you for marketing purposes, you can object to these communications at any time.

In detail: In any case, you always have the option to object to the sending of these commercial emails by clicking on the unsubscribe link provided in each e-mail or by writing to us at the following address: privacy@epitaph.com. Please note that, notwithstanding the promotional preferences you indicate by either unsubscribing or opting out, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

9.2-3 – Your RIGHT TO LODGE A COMPLAINT

If you think that we are doing something wrong, you can complain to us about it, by contacting our Data Protection Officer. In the event of an unsatisfactory response, you can lodge a complaint with our Lead Supervisory Authority in the Netherlands:

Autoriteit Persoonsgegevens
PO Box 93374
2509 AJ DEN HAAG
Telephone number: (+31) - (0)70 - 888 85 00


9.3 – DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION

In short: Insofar as we are a US-based organization, the Personal Data we collect when you use our website is processed in the United States.

In detail: We may receive Personal Information from you from our European branch in the Netherlands. We may also receive Personal Information from our business partners, artists or record labels located in the European Union. The transfer and follow-up policy are carried out in accordance with this Privacy Policy and that it is framed by standard contractual clauses of the European Commission which make it possible to guarantee a sufficient level of protection of your privacy and fundamental rights. You may request access to these standard contractual clauses by contacting us at privacy@epitah.com. You may also consult the standard terms by following this link.

10 – ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS (CCPA)

The content below is intended only to apply to visitors, users, and others who reside in the State of California and is adopted to comply with the standards enforced by the California Consumer Protection Act of 2018 (CCPA). It is construed as a supplement to and not a replacement for our complete Privacy Policy.

For the purposes of 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.

It does not apply to Personal Information that we collect from you in the course of providing our services when you are an employee, owner, director, manager or entrepreneur of a company, a partnership, a sole proprietorship, a non-profit organization or a public body.

10.1 – TO WHOM WE MAY DISCLOSE AND/OR SELL YOUR PERSONAL INFORMATION

Under the CCPA, a “sale” is broadly defined as the disclosure of Personal Information for monetary or other valuable consideration and may include certain of our business practices, including those related to certain types of online advertising.

In the preceding 12 months, we disclosed for our operational business purposes or sold the following categories of Personal Information to the following categories of third parties:

CATEGORIES OF PERSONAL INFORMATIONDISCLOSED TO WHICH CATEGORIES OF THIRD PARTIES FOR OPERATIONAL BUSINESS PURPOSESSOLD TO WHICH CATEGORIES OF THIRD PARTIES
Identifiers (name, contact information (address, email address, telephone number, an IP address that can reasonably be linked to you, social media username or handle, and online identifiers). Affiliates; Service Providers; Business Partners; Promotion Sponsors; Ad NetworksAd Networks
Customer Records Information (name and contact information).Affiliates; Service Providers; Business Partners; Promotion Sponsors; Ad NetworksAd Networks
Transaction Information (listening history and preferences). Affiliates; Service Providers; Business Partners; Promotion Sponsors; Ad NetworksAd Networks
Online Use Information (Internet or network activity information, such as browsing history, search history, and interactions with our online properties or ads).Affiliates; Service Providers; Ad NetworksAd Networks
Inferences (drawn from any of the Personal Information listed above to create a profile or summary about you, for example your preferences). Affiliates; Service Providers; Ad NetworksAd Networks

10.2 – HOW TO EXERCISE YOUR RIGHTS OF ACCESS AND DELETION

In short: Subject to certain exceptions and restrictions, you have the right to ask us to delete your Personal Information, or to provide you with information on the Personal Information that we have collected, our sources of collection, the business and commercial purposes for which this information was collected, and the categories of third parties with whom this information has been shared.

In detail: If you are a California resident and wish to exercise these rights, please follow the instructions below.  

Making a verifiable request does not require you to create an account with us. You may contact us at privacy@epitaph.com or fill-in our Data Subject Request Form to exercise your rights.  

We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as your driver’s license or a State issued ID.

You may designate an authorized agent to exercise your rights on your behalf. We may ask you or the agent to provide proof that the agent has received your authorization to act on your behalf, such as a written and duly signed certificate stating you authorize the agent to act on your behalf. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.

We will respond to your request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account

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.



10.3 – HOW YOU CAN ASK US NOT TO SELL YOUR PERSONAL INFORMATION 

In short: As explained above, we may sell your Personal Information to third-party organizations. You can object to such sale of your Personal Information.

In detail: You can opt out of the sale of your Personal Information by clicking on the “Do not sell my Personal Information” link in the widget on our website or fill out the form here. We will stop the sale of your Personal Information no later than 15 days following your request.

We will not discriminate against you in case you decide to exercise your rights, which means that we will not:

  • Deny you goods or services;

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

  • 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.

With respect to the right to opt-out from receiving promotional communications from us, please allow ten (10) business days for your request to be processed. Even after you opt-out from receiving promotional messages from us, you may continue to receive transactional and product-related messages from us regarding our services.  

You may designate an authorized agent to exercise your right to opt out of a sale on your behalf. We may ask you or the agent to provide proof that the agent has received your authorization to act on your behalf, such as a written and duly signed certificate. Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.