Effective June 1, 2023

Introduction

Centercode’s GoEarly Program is a program where customers desiring to have early access to unreleased Centercode Platform features are given early access in exchange for their feedback about these upcoming features. You have arrived on either our Centercode-branded GoEarly Program Platform or a mock test or demo site we have provided you with access to for purposes of participating in our GoEarly Program, (each, a “GoEarly Program Platform”) because you have agreed to serve as a GoEarly Program test participant or are otherwise creating a user account as a part of our GoEarly Program on behalf of our customer that is or wishes to become a GoEarly Program member, or because you have otherwise decided that you are interested in becoming a GoEarly test project participant. 

In order for you to create an account and become a GoEarly Community Member on this GoEarly Program Platform, we collect and manage some personal information about you. Our continuous goal is to handle your personal data as respectfully and responsibly as possible, while being completely transparent as to what exactly that means.

We also understand that privacy is a complex subject, and focusing strictly on the legal details doesn't necessarily highlight the items that are most important to you. Given that context, we've deliberately split our policy into two parts. The first section is intended to provide a plain-English overview of the topics that we feel are most interesting to our GoEarly Community Members. The next section provides you with the comprehensive details. 

Regardless, we comply with and are passionate about this entire policy, and would encourage you to take your time in reviewing this entire policy. Also, please don't ever hesitate to reach out to us at privacy@centercode.com if you have any feedback or questions. If you don't agree with any aspect of this policy, you should not join the GoEarly Program Community or opt out.

Key Terms

  • The GoEarly Program Platform is an online portal that allows individuals to apply for and/or test new features of the Centercode Platform as a part of GoEarly test projects. The term GoEarly Program Platform also includes any mock test or demo site we have provided you with access to for purposes of participating in our GoEarly Program. The GoEarly Program Platform and the Centercode Platform are owned and managed by Centercode. By becoming a GoEarly Community Member, you're expressing an interest in participating in GoEarly Program test projects. 
  • Your GoEarly Program Platform Profile is comprised of data that you directly provide to the GoEarly Program Platform. This includes Personal Profile data, such as account (e.g. name, email) and demographic information (e.g. gender, age), and test platform data, which describes things you own or have access to (e.g. your phone, house, or computer) that may be relevant to your testing of the Centercode Platform. This information is used to contextualize the feedback you provide in any tests that you participate in through the GoEarly Program and to contact you. We don't ever sell your information.
  • Test Feedback includes everything you provide when applying for, and participating in a specific test within the GoEarly Program Platform. This typically takes the form of things like bug reports, feature suggestions, file uploads, and survey responses. This is the information we need to improve our Centercode Platform features. By providing this information, it's important that you understand that we will own the feedback that you provide. 

Key Concepts

  1. Profile information provided to us is used to identify appropriate candidates for tests of the Centercode Platform and to contact the GoEarly Community Members. From time to time we may also use it for aggregate research purposes. We don't sell or share this information for purposes other than these tests. Beyond your basic member profile, you can choose how much information you provide.
  2. While participating in a GoEarly Program test, your full name will be used to identify you, including in communications and activities visible between test participants. Note that our tests are typically run in a very collaborative nature, and therefore anonymity of your name and your feedback shouldn't be expected. In other words, if you're not comfortable with other testers knowing who you are, you shouldn't participate in the GoEarly Program.
  3. While your company’s GoEarly Program Engagement Agreement, where applicable, highlights the participation requirements for that company receiving early access to Centercode Platform features, if at any point you would like to remove your personal account from the GoEarly Program Platform, you're absolutely free to do so. Upon leaving, your personal information will be wiped completely, but you will still have access to any agreements you've already completed (and we will still have access to your personal information in those agreements).

Detailed Policy

This policy describes how Centercode collects, uses, and discloses information it collects as a part of its GoEarly Program, and the choices you have about the information we collect. When we refer to Centercode, we mean Centercode, Inc., a California corporation. Centercode owns and operates the web-based GoEarly Program test participation portal known as the GoEarly Program Platform and any mock test or demo site we have provided you with access to for purposes of participating in our GoEarly Program (each, a “GoEarly Program Platform”). 

We use the GoEarly Program Platform to collect, organize, and announce customer testing opportunities that exist for our own Centercode Platform as a part of our GoEarly Program, during which you can test the features of our Centercode Platform and provide us with feedback. We also use the GoEarly Program Platform to register and collect information about GoEarly Community Members (account holders) interested in participating in customer tests through our GoEarly Program. We use GoEarly Program Platform demo or test sites in some tests to provide you with a different experience interacting with the Centercode Platform.

Centercode also owns and operates Betabound, betabound.com and its web-based test participation portal known as Betabound, which we use to announce a wide variety of third-party product and service testing opportunities, and to register and collect information about individuals interested in participating in these tests. We also own and operate the Centercode.com website. Our Betabound offerings and your interaction with us through centercode.com are outside of the scope of this GoEarly Program Privacy Policy (see Scope). In addition, Centercode also owns and operates the cloud-based software platform known as the Centercode Platform used by other customers to test their own products and services. Your use of one of our customers’ Centercode Platform implementations is also outside of the scope of this GoEarly Program Privacy Policy (see Scope).

You should read this entire privacy policy. If you do not agree to its terms, you should not use the GoEarly Program Platform. By using the GoEarly Program Platform and/or providing data to us in connection with the GoEarly Program, you are accepting and agreeing to the practices outlined in this privacy policy.

Table of Contents

Introduction
Detailed Policy
Scope
The Data We Collect and Receive
How We Use and Share Personal Data
Cookies, IP Addresses, and Other Passive Information Collected
Security
Removing Your Account
Data Retention
Data Modification, Deletion, and Other Rights of European Residents
California Privacy Rights
Data of Children
International Transfer of Data
Changes to Our Privacy Policy
Questions or Concerns

Scope

This privacy policy describes our privacy practices concerning the information that we collect through or related to the GoEarly Program Platform and emails and other communications with you related to your participation in the GoEarly Program (collectively, the GoEarly Program Sites). 

This policy does not describe our privacy practices related to centercode.com, and our Centercode social media pages (collectively, the Centercode Sites), and information we gather related to Centercode employment, vendor relationships, and business services other than our GoEarly Program. Please visit the Centercode Privacy Policy to learn about the privacy practices that apply in these contexts.

This policy does not describe our privacy practices for the information that we collect through or related to betabound.com, including its web-based test participation portal, and related social media pages, emails, or other communications  (collectively, the  Betabound Sites). Please visit the Betabound Privacy Policy to learn about the privacy practices that apply in these contexts.

Finally, we offer our platform to subscribing customers that use their own instance of the Centercode Platform to develop and manage their own test communities and customer testing programs. Their use of our platform and the use by their authorized users is outside the scope of this privacy policy. If you encounter our platform outside of the GoEarly Program, you should review the privacy policy of the company using our platform before creating an account. To learn more about the data that we hold and process for our customers on their behalf, please review our Customer Data Handling Practices.

The Data We Collect and Receive

In order to operate and enable your use of the GoEarly Program Platform, manage our GoEarly Program and the testing of the Centercode Platform through that program, contact you about the GoEarly Program, and for other legitimate business interests described in this policy, we receive and collect certain information from you and about you, including GoEarly Program Platform Profile information, Test Feedback, and other information, which includes Personal Data.

Except as described below for California consumers, when we use the term Personal Data, we mean information that identifies an individual or that relates to an identified or identifiable individual (e.g. name, email address, phone number, location data, mailing address). 

By submitting or providing Personal Data or other information to us, you are representing that you have authority to do so and that we have full authorization to use this information in accordance with this privacy policy, even if the information relates to other individuals or entities. You agree to provide and maintain complete and accurate information, and understand that you are solely responsible for the data that you provide to us.

GoEarly Community Member Information

In order to create a GoEarly Community Member account, we require you to provide both basic account information (such as your first and last name, email address, username and password, time zone, country, and date of birth).

At different times, we may also ask you to complete voluntary and optional surveys seeking more information, including Personal Data, (such as address, phone number, languages spoken, social media handles, home ownership and family information, details about your education, employment information, testing interests, and similar information) about your interest in and qualifications for tests that may be conducted by us as a part of our GoEarly Program. 

We own and control the information that you provide as a part of your GoEarly Community registration, profile, and completion of other GoEarly Program Community Member surveys, questionnaires, and agreements. We call this information your GoEarly Profile. We also own and control your Test Feedback (any information that we collect or you provide during or in connection with applying for, and/or participating in a specific test in our GoEarly Program). We use and share this information as described below in How We Use and Share Personal Data. 

Becoming a GoEarly Community Member and joining our GoEarly Program is entirely voluntary. While your company’s GoEarly Program Engagement Agreement, where applicable, highlights the participation requirements for receiving early access to Centercode Platform features, if you do not wish to provide the required information, you should not become or remain a GoEarly Community Member. If you do not wish to provide any optional additional requested information, you should not do so.

Other Information Collected

As you interact with us regarding your GoEarly Community Member account or your interest or involvement in the GoEarly Program, such as through emails and other communications outside of your GoEarly Community Member account, we may gather Personal Data from you, such as your name, phone number, and email address, and any other information you voluntarily provide to us.

How We Use and Share Personal Data

This section describes how we use and share information within the scope of this policy. 

GoEarly Community Member Information

When you provide your email to us during the GoEarly Program Platform registration process, you are agreeing to allow us to use the information that you provide, including Personal Data, to contact you regarding participation in customer tests that we conduct as a part of our GoEarly Program. 

We may also send you newsletters, announcements, or communications, including by email and text message, that we believe may be of interest to you regarding our GoEarly Program. While your company’s GoEarly Program Engagement Agreement highlights the participation requirements for receiving early access to Centercode Platform features, if at any time you no longer wish to receive updates, notifications, or other communications about the GoEarly Program, where applicable, you can follow the instructions under Removing Your Account below to terminate your GoEarly Community Member account.

In addition, sometimes during a test, a subset of your Personal Data may be shared with other GoEarly Program test participants where the test includes collaborative activities, such as group chats and discussions. During these activities, selected GoEarly Profile information, which can include your full name, username, and any text or file-based feedback you provide in that group activity, may be visible to other participating testers. If you are not comfortable with this, do not participate in the group activity or share text or files in the group activity.

Contact Information

We use contact information that you have provided to us through the GoEarly Program Platform or through your business or other contacts you have provided to us in connection with the GoEarly Program in order to contact you to discuss GoEarly Program matters. For example, we might send you announcements of GoEarly Program test opportunities and events regarding the GoEarly Program, or for additional Feedback. We may also send you GoEarly Program newsletters and updates.

Other Use and Sharing

We may also use or share information you provide to us for other legitimate interests including

  • to create an account you have requested;
  • to send administrative information to you, such as changes to our terms, conditions, and policies;
  • to respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information about our services and businesses;
  • to service your account, including maintaining records of any agreements you enter into;
  • to communicate with you and provide you with all necessary or helpful information;
  • to personalize your experience on the GoEarly Program Platform, such as by presenting opportunities or content tailored to you;
  • regarding the general level of participation of GoEarly Community Members in tests that we conduct in the GoEarly Program;
  • for other internal business purposes, such as data analysis, audits, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, network, information, and system security, debugging, developing new products, enhancing, improving or modifying the Centercode Platform, our GoEarly Program Platform, and or GoEarly Program, identifying usage trends, determining the effectiveness of our GoEarly Program, and operating or expanding our business activities;
  • in connection with company transactions such as asset sales, reorganizations, mergers, joint ventures, assignments, financings, dispositions of stock, and other changes of control, where Personal Data and other information is transferred to third parties for legitimate purposes in connection with the transactions;
  • as we believe to be necessary or appropriate under applicable law, including laws outside of your country of residence, to comply with legal process, to respond to the requests of courts or governmental authorities, to enforce our terms and conditions, to protect our operations, rights, privacy, safety, customers, or property (or that of others), and to allow us to pursue available remedies or limit damages we may sustain; and
  • for other purposes you have specifically agreed to.

Aggregated or De-Identified Information

Where data is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, we may use and disclose it for any business purpose, except as otherwise prohibited under applicable law. Typically this would be used for research purposes, or to promote our community, but we may have other business uses.

How We Share Data with Our Third-Party Service Providers and Partners

We contract with third-party service providers and partners who provide services to us in accordance with our instructions, including our cloud hosting provider for the GoEarly Program Platform (Amazon Web Services), general office services such as email and file storage (Google), providers for customer support content and management (Hubspot and Insightly), and similar service providers. Our third party service providers have access to your data (including Personal Data) for the purpose of providing services to us and in compliance with our documented instructions. We diligently choose these third-party service providers, evaluate their privacy, security, and confidentiality practices, and enter into agreements with them specifying their obligations. 

Cookies, IP Addresses, and Other Passive Information Collected

Like many companies, we use cookies (small data files stored on your computer), logging, and similar tools to collect and analyze information about community members. This information is used to operate the GoEarly Program Platform, to prevent fraud and misuse of our services, to measure how people use the GoEarly Program Platform, to analyze trends, to improve the GoEarly Program and our services, and to improve your overall GoEarly Program experience. 

GoEarly Program Platform Mandatory Session Cookies and Usage Data

When accessing your account on the GoEarly Program Platform, the platform uses session cookies to grant you access to, and secure your account. These cookies allow us to uniquely identify you following the entry of your username and password so that you may access your account. Session cookies are required in order to use the GoEarly Program Platform.

In addition, when you log in to your account, our servers automatically log typical HTTP information, including your Internet Protocol (IP) address, a unique device identifier (a UUID), your device name, operating system type and version, network type, country of origin, information about how you use your account (e.g. the pages you view, the links you click, the dates and times of your requests and referral URL, and other actions you take), the error messages you receive or problems you encounter, and similar data. 

We use this information to provide our services and support to our customers and users. We also use this information to monitor the regions from which you navigate your account, to identify you when you are using your account, to enhance our security and service performance, and for audit, compliance, investigations, and account support purposes. 

We also use de-identified or aggregated log data gathered about the general use of the GoEarly Program Platform for internal business purposes such as developing and enhancing our products and services, identifying usage trends, and for other legitimate business purposes. 

Do Not Track

We do not currently respond to "Do Not Track" browser signals.

Security

We take the security of the Personal Data that we hold very seriously. We maintain a written security policy for the security, integrity, and protection of the Personal Data we hold against unauthorized disclosure or loss. We have put in place physical, technical, and organizational processes and measures designed to safeguard all Personal Data. When accessing an account on the GoEarly Program Platform via a supported web browser, Transport Layer Security (TLS) is used to protect information using both server authentication and data encryption to help ensure data is safe and secure in transit. We host the GoEarly Program Platform, on cloud-based servers located in a secure data center environment using a firewall and other advanced technology designed to prevent interference or access from outside intruders. We also require verified email addresses, unique usernames, and strong passwords for account authentication.

These safeguards help prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the Personal Data that we hold. However, you should be aware that no security procedures or protocols are guaranteed to be 100% secure, and there is always some risk assumed when you share information. You are responsible for maintaining the confidentiality and security of your username and password. 

If you have reason to believe that your interaction with us is no longer secure, your account has been compromised, or you would like more information about our security practices, please contact us immediately. In the event that any Personal Data under our control is compromised as a result of a breach of security, we will investigate the situation and, where appropriate or required by law, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws and regulations. 

Removing Your GoEarly Program Platform Account

If you would like to remove your GoEarly Program Platform account entirely, you can do so by using the Remove Your User Account feature on the right side of your Account Settings page, or by navigating to https://goearly.centercode.com/optout. Where your company is participating in our GoEarly Program and receiving early access to unreleased Centercode Platform features, to ensure your company’s compliance with the requirements to participate in this early access program, we ask that you also contact your company’s appointed Functional Solutions Consultant (FSC) or email goearly@centercode.com to arrange for any necessary replacement representative from your company or to arrange for the offboarding of your Centercode site from the GoEarly Program. 

If you have another request regarding your Personal Data, please notify us at privacy@centercode.com so that we may consider and respond to your request in accordance with applicable law.

Data Retention

We will retain your Personal Data for a period consistent with the original purpose of collection, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes, and enforce applicable agreements. For example, we will retain GoEarly Profile information, Test Feedback, and other information collected in connection with your GoEarly Program participation as long as you maintain a GoEarly Program Platform account, and thereafter for the period of time that we need to pursue legitimate business interests, conduct audits, comply with and demonstrate compliance with legal obligations, resolve disputes, and enforce agreements. 

Deleted data stored in our backup systems will be automatically deleted within a reasonable period of time during our backup procedures, except as otherwise required by applicable law.

Data Modification and Deletion; Other Rights of European Residents

GoEarly Community Members may log in to their accounts to delete or amend certain types of Personal Data and information in their GoEarly Profile at any time using the functionalities provided. 

Individuals located in certain countries and localities, including those residing in the European Union, the European Economic Area, the United Kingdom, and Switzerland (“European Residents”), have certain statutory rights regarding their Personal Data. For European Residents, reference to Personal Data in this privacy policy is equivalent to “Personal Data” as defined in the EU General Data Protection Regulation or any successor or enacting legislation (the “GDPR”). 

Subject to any exemptions provided by law, these individuals may have the right to request access to their Personal Data, or seek to update, delete, or correct Personal Data. If your request relates to Personal Data that we control within the scope of the GDPR, such as GoEarly Profile information of a European Resident, your rights may be exercised by contacting us at privacy@centercode.com. Any European Resident who is dissatisfied with our handling of a request regarding Personal Data within the scope of the GDPR, has a right to lodge a complaint with his or her local data protection authority responsible for monitoring the application of the GDPR. 

For your protection, we may need to take additional steps to verify your identity before implementing any request relating to your Personal Data. If you have designated an authorized agent to exercise your rights on your behalf, please note that to protect your Personal Data, we will need to verify that your authorized agent has permission from you to make requests on your behalf, and we may need to also verify your authorized agent’s identity. If we are unable to do so, and you have not received a response from us, please contact us directly regarding your request. We will respond to your request promptly, and in no more than 30 days from your request, subject to applicable law. Please note that we may need to retain certain information for recordkeeping purposes, such as retaining copies of agreements you have entered into with us and/or for audit and investigation purposes, or in the event of a court order or requirement of law. 

Deleted or updated Personal Data stored in our backup systems will be automatically deleted or updated within a reasonable period of time during our backup procedures, except as otherwise required by applicable law.

California Privacy Rights

This section applies to California consumers. It describes how we collect, use, and share California consumers' Personal Information in connection with the GoEarly Program in our role as a business, and the rights applicable to such residents. If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access. For purposes of this section Personal Information has the meaning given in the California Consumer Privacy Act (the “CCPA”).

Categories of Personal Information

We have collected the following statutory categories of Personal Information in the past twelve (12) months:

  • Identifiers, such as first and last name, mailing address, email address, user identification, and phone number. We collect this information directly from you. 
  • Protected legal characteristics, such as age/date of birth and sex and/or gender. We collect this information directly from you.
  • Commercial information, such as information about products and services you purchased, obtained, or considered purchasing that might be relevant to testing. We collect this information directly from you. 
  • Internet activity or network information, such as browsing and search history within the GoEarly Program Sites, and information about your interaction with our GoEarly Program Platform. We collect this information directly from your device. 
  • Geolocation data, such as your physical address that you provide to us, and by receiving IP address information from your device.
  • Audio and visual data in the form of photos, videos, and audio-recordings, that you provide to us in the course of a test. We collect this information directly from you.
  • Employment information, such as your employer and employment history. We collect this information directly from you.
  • Education information, such as your educational level. We collect this information directly from you.
  • Inferences. 
  • Other Personal Information you voluntarily provide to us in instances when you interact with us through the GoEarly Program Platform or other online methods, by phone, chat, email, or mail in the context of receiving help through our support channels or offering feedback to us through the GoEarly Program Platform. 

How We Use and Share Your Personal Information

The business and commercial purposes for which we collect this information are described above in How We Use and Share Your Personal Data. The categories of third parties that have access to this information as our service providers for a business purpose are described above in How We Use and Share Your Personal Data.

Your California Rights

You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law. 

  • Right of Access and Data Portability Rights: You have the right to request that we disclose what categories of Personal Information we have collected, used and disclosed about you in the past 12 months, including:
    •  the categories of sources for this Personal Information, 
    • our legitimate business or commercial purpose for collecting or sharing this Personal Information, 
    • the categories of third parties with which we share this Personal Information, 
    • the specific pieces of your Personal Information we collected about you, and
    • if we sold or disclosed your Personal Information for a legitimate business purpose, 
      • a list disclosing the sale(s) that identifies the Personal Information that each category of recipient purchased, and 
      • disclosures made for a legitimate business purpose, identifying the Personal Information categories that each category of recipient obtained.
  • Right of Deletion: You have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. 
  • Right to Non-Discrimination: You will not receive any discriminatory treatment when you exercise one of your privacy rights under the CCPA.

Centercode does not sell your Personal Information to third parties. We engage certain trusted third parties to perform functions and provide services to us. We may share your Personal Information with these third party service providers, but only to the extent necessary to perform these functions and provide these services. We require these third parties to maintain the privacy and security of the Personal Information they process on our behalf. These disclosures for business purposes include disclosures of all Personal Information categories described above for auditing/compliance, hosting of the GoEarly Program Sites and maintenance/security services, error monitoring, debugging, and performance monitoring, and your full name, username, and email (and any other category of Personal Information you voluntarily provide) for communication with you about your account and other support. In addition, in the context of your interactions with other participants through GoEarly Program test projects, your full name, username, and any other category of Personal Information you voluntarily provide in connection with group activities may be visible to other test participants. 

How to Exercise Your California Rights

If you would like to access this policy in an alternative format or wish to exercise your California rights, please contact us at privacy@centercode.com or by the methods provided in Questions or Concerns below. 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. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 

The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected the Personal Information or a registered representative, and must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to your request. 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.

Data of Children

The GoEarly Program Platform is not intended for use by minors under the age of 18. We do not knowingly or specifically collect information from these minors through the GoEarly Program Platform or otherwise. If you believe that we have mistakenly or unintentionally collected information from minors or have any questions or concerns regarding the use of our services to collect information from minors, please contact us at privacy@centercode.com so that we may investigate and delete the information from our servers as necessary. 

International Transfer of Data

The Personal Data and other information we collect from you is used, stored, and/or processed by us in the United States, where we are located. In addition, in the circumstances described in this privacy policy where your Personal Data and other information is transferred to a third party, this data may also be used, stored, and/or processed outside of the United States in any country in which the third party has facilities or engages service providers. These countries may not offer the same legal protections offered in your country and may be considered by your country to offer insufficient legal protections. 

European Residents have a right to withdraw their consent to cross-border transfers of their data, and if you wish to do so with respect to your Personal Data that we control, you may contact us at privacy@centercode.com. The withdrawal of consent will not affect the lawfulness of actions based on your consent prior to your withdrawal. 

Changes to Our Privacy Policy

We reserve the right to change this privacy policy. If we make changes to this policy, you will find the revised privacy policy posted on the GoEarly Program Platform, along with the effective date of the revised privacy policy. Your use of and access to the GoEarly Program Platform after any changes become effective will be considered your acceptance of those changes and will constitute your agreement to be bound by the new or modified privacy policy.

Questions or Concerns

Questions about this Privacy Policy or our information practices should be directed to Centercode by emailing privacy@centercode.com or by mailing us at 23422 Mill Creek Drive, Suite 105, Laguna Hills, CA 92653 ATTN: Privacy Policy. Alternatively, to communicate with our Data Protection Officer, please email dpo@centercode.com, or by mail at 23422 Mill Creek Drive, Suite 105, Laguna Hills, CA 92653 ATTN: DPO, or by phone at (800) 705-6540.