Last updated: January 1, 2023

This California Supplemental Privacy Notice (“Notice”) supplements the information in and forms part of the Twingate Privacy Policy (“Privacy Policy”). This Notice applies solely to California residents. This Notice applies to all products, services, apps, and websites that link to our Privacy Policy, except where otherwise noted.

1. Your California Privacy Rights

1.1. Do Not Track Signals

Twingate currently does not respond to “Do Not Track” signals sent by browsers or mobile apps due to a lack of standardization regarding how that signal should be interpreted. Learn more about Do Not Track.

Please note that Do Not Track is a different privacy mechanism than the “Global Privacy Control” browser choice referenced below in the “Your Choices Regarding ‘Sales’ and ‘Sharing’” section, which is a browser-based control that indicates whether you would like to opt out of processing of your personal information for certain online behavioral advertising or analytics purposes.

1.2. Third Party Disclosure Requests

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their “personal information” (if any) as defined under California Civil Code 1798.83 for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. See the “Contact Us” section below for where to send such requests. Note that Twingate does not disclose personal information to third parties for their own direct marketing purposes without your prior consent.

1.3. Your Choices Regarding “Sales” and “Sharing”

Under the CCPA, “selling” personal information has a specific definition that may cover our use of some advertising and analytics technologies (such as Google Analytics). We engage in these activities, for example, to understand the effectiveness of our marketing and advertising campaigns on digital ad networks.

Under the CCPA, ”sharing” includes the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites. We “share” information for these purposes to provide more relevant and tailored advertising to you regarding our services.

To opt out of our “sale” of your personal information or our “sharing” of your personal information for purposes of cross-context behavioral advertising, view this page.

Please note that we also respond to and abide by Global Privacy Control (GPC) signals on this domain as a form of opt-out preference signal. Any opt out preferences you have exercised through these methods will only apply to the specific device or browser on which you made them.

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

Please see the “Your Rights” section of our Privacy Policy for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

1.4. Additional Rights

California law may permit you to request that we:

• provide you the categories of personal information we have collected or disclosed about you in the last twelve months, the categories of sources of such information, the business or commercial purposes for collecting, “selling” or “sharing” your personal information, and the categories of third parties to whom we “sold” or “shared” personal information. This information is provided in this Notice;

• provide access to, or a copy, of certain information we hold about you;

• delete certain information we have about you.

You may also have the right to receive information about the financial incentives that we offer to you (if any), and the right to not be discriminated against (as provided for in the CCPA) for exercising certain of your rights.

Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the services to you and for compliance with applicable law.

When you exercise certain rights, we may take reasonable steps to authenticate your identity before fulfilling your request (such as verifying your email address or payment instrument). If you ask us to delete certain information, you may no longer be able to access or use our services.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with a signed, written permission to make such requests, or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at:

Twingate Inc., 541 Jefferson Ave, Suite 100, Redwood City, CA 94063, United States

Email: privacy@twingate.com

2. Summary of How we Handle your Personal Information

The California Consumer Privacy Act (CCPA) requires that we make certain disclosures to California residents, including the categories of personal information we collect, the purposes for which we use that information, the categories of sources of personal information, and the categories of third parties to whom we disclose personal information for a business purpose, “sell” personal information, or “share” personal information for cross-context behavioral advertising (as described above). This section lays out this information in the manner specified by the CCPA, but it does not differ in substance from the information we provide in our Privacy Policy.

2.1. Sources of Personal Information

All the categories of personal information we collect come from the following categories of sources:

• You (either via voluntary submission or automatic collection, such as when you use our services)

• Our affiliates within the Twingate family of companies

• Third parties (such as service providers, public sources, other users or marketing partners who may refer you to our services, and your organization if they are a Twingate customer)

2.2. Uses and Disclosures of Personal Information

For more information about each category, purpose of use, and the third parties to whom we disclose information, please see Section 1 (“What information do we collect about you?”), Section 2 (“How do we use your information?”), and Section 3 (“Who do we disclose your information to and why?”) of our Privacy Policy.

2.3. Retention of Your Personal Information

Please see Section 7 (“Data Retention”) of our Privacy Policy.