Supplemental Privacy Statement (California Residents Only)

Updated: 18 September 2023

U.S. Supplemental Privacy Statement 

Summary: In this Supplemental Privacy Statement, we disclose our data privacy practices in a format acceptable for United States residents including residents of California, Virginia and Colorado. Each state provides slightly different rights to their residents; however, our data privacy standards and practices do not change based on where you live. If you are a resident of either state, please review the entire U.S. Supplemental Privacy Statement to understand how we collect, manage, use and otherwise share your personal data, and please see your specific state rights as indicated by the headings below. If you have any questions, please do not hesitate to email us at [email protected] or call us at: SI +386 1 828 4998, UK: +44 330 053 3405, US: +1 (619) 391 9229.  This privacy statement applies to our websites (https://www.ekwb.com/, ekfluidgaming.com, b2b.ekwb.com, ekcoolingsolutions.com) and associated services, hereinafter referred to as “Websites” and “Services'' respectively.

California Residents’ Supplement

California "Shine the Light" Law

California Civil Code § 1798.83 (the "Shine The Light" law) permits consumers, who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as the Shine the Light law defines), if any, that we disclosed in the preceding calendar year to third parties for those third parties' direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. Currently, we do not disclose personal information for this purpose. Still, if you are a California resident and would like to make such a request, please contact us via our email address below.

California Consumer Privacy Act Statement

Under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”), California residents have certain rights around our collection, use, and sharing of their personal information (hereinafter “Personal Data”). We do not sell your Personal Data and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, as a matter of normal business activities, we do not offer financial incentives associated with our collection, use, or disclosure of your Personal Data. Occasionally we may run sweepstakes as a means of collecting Personal Data, and we will disclose the terms of those sweepstakes separately. As of January 1, 2023 you have the right to opt-out of sharing your Personal Data with third parties for the purposes of targeted behavioral advertising, which you can do by clicking here https://www.ekwb.com/shop/do-not-sell-my-info/. We collect various categories of Personal Data when you use the Service, including identifiers, commercial information, internet or other electronic network or device activity information and more.

 A more detailed description of the information we collect and how we use it is provided below in the “Information We Collect” and “How We Use Personal Data” sections. The “How We Disclose Personal Data” section describes the categories of third parties with whom we share Personal Data, and what information may be shared under different circumstances. If you are a resident of California, you have the right to request to know what Personal Data has been collected about you, and to access that information. You also have the right to request deletion of your Personal Data, though exceptions under the CCPA may allow us to retain and use certain Personal Data notwithstanding your deletion request. As of January 1, 2023 you have the right to request correction of inaccurate Personal Data and to request to limit disclosure or use of your sensitive Personal Data.

Do Not Track Disclosures

We do not currently respond to browser Do Not Track signals or other browser or device based mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. Unless and until the law requires us to respond to browser Do Not Track signals, we will not respond to those signals as an opt out, but if we do so in the future, we will describe how we do so here. However, we do provide consumers with the ability to manage their cookie choices as described in our Cookie Policy For more information on Do Not Track, please visit www.allaboutdnt.com.

Third Party Links

Our Websites or Services may contain links to other websites or services that are not owned or controlled by us, including links to social media platforms, or may redirect you off our Website away from our Services to other websites for information or other services. This Privacy Policy only applies to information collected by our Websites and Services. We are not responsible for the privacy and security practices of those other websites or social media platforms or the information they may collect (which may include IP address). You should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other website’s or content do not constitute or imply an endorsement or recommendation by us of the linked website, social media platform, and/or content.

This EKWB California Privacy Statement supplements EKWB’s Privacy Policy and applies solely to California residents who visit or use our Website. If you are a California resident, the California Consumer Privacy Act (“CCPA”) grants you various rights regarding your personal data.

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 Data”).

Categories of Information We Collect

In particular, we have collected the following categories of Personal Data from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope.

Sources of the Information We Collect

We obtain the categories of Personal Data listed above from the following categories of sources:

• Directly from our clients or their agents, such as from documents that our clients provide to us related to the Services or products for which they purchase.
• Indirectly from our clients or their agents, such as through information we collect from our clients in the course of providing Services to them.
• Directly and indirectly from activity on our Websites (https://www.ekwb.com/, ekfluidgaming.com, b2b.ekwb.com, ekcoolingsolutions.com), such as from submissions through our Website portal or Website usage details collected automatically.
• From third-parties that interact with us in connection with the Services we perform.

How We Use Personal Data

We may use or disclose the Personal Data we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided;
• To provide you with information, products, or Services that you request from us;
• To provide you with email alerts and other notices concerning our products or Services that may be of interest to you;
• To improve our Website and deliver its contents to you;
• For testing, research, analysis and Product development;
• As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your Personal Data or as set forth in the CCPA.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Our Retention of Personal Data

We will retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. In determining the appropriate retention period for Personal Data, we will take into account the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, and the purposes for which we process your Personal Data. We will also take into account any applicable legal requirements, such as retention periods prescribed by law or regulation. We will securely delete your Personal Data when it is no longer needed for these purposes.

How We Disclose Personal Data

We may disclose your Personal Data to a third party for a business purpose. When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. Your Personal Data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside the United States, and may have different data protection laws than in the United States.

We disclose your Personal Data for a business purpose to the following categories of third parties:

• Our affiliates;
• Service providers; and
• Third parties to whom you or your agents authorize us to disclose your Personal Data in connection with our Services.

Sale of Personal Data

We do not sell any Personal Data (over the previous 12 months or otherwise)

Your Rights and Choices

The CCPA provides consumers, who are California residents, with specific rights regarding their Personal Data.

Access to Specific Information and Data Portability Rights

You may request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Data we collected about you;
• The categories of sources for the Personal Data we collected about you;
• Our business or commercial purpose for collecting or selling that Personal Data;
• The categories of third parties with whom we share that Personal Data;
• The specific pieces of Personal Data we collected about you (also called a data portability request); and
• If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Data categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.

Deletion Request Rights

You may request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your Personal Data from our records, unless an exception applies.

Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.

Right to Opt-Out of Targeted Advertising

As of January 1, 2023 you have the right to opt-out of sharing your Personal Data with third parties for the purposes of targeted behavioural advertising, which you can do by clicking on the “Do Not Sell Or Share My Info” link here or elsewhere on our Website, where you will find instructions on opting out of the use of your personal data.

Exercising Your Rights

To exercise your rights to know or delete described above, please submit a request by either:

• Calling us at:

       SI: +386 1 828 4998,

       UK: +44 330 053 3405,

       US: +1 (619) 391 9229

• Emailing us at [email protected]

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative, which may include, but is not limited to, Personal Identifiers, government issued identification, usernames and passwords, or other Personal Data. You will also need to describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Our Response - Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at [email protected] or call us at: SI +386 1 828 4998, UK: +44 330 053 3405, US: +1 (619) 391 9229. We try to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, 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 the contact associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

Non-Discrimination

We will not discriminate against you for exercising any of your statutory rights. Unless the law permits, we will not:

• Deny you products or services.
• Charge you different prices or rates for products or services.
• Provide you a different level or quality of products or services.
• Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.

Changes to Our Privacy Statement

We reserve the right to amend this privacy statement at our sole discretion. We will make any and all changes available through our Website.

Contact Information

If you have any questions or comments about this statement, our Privacy Notice, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, or wish to exercise your rights under state law, please email us at: [email protected] or call us at: SI +386 1 828 4998, UK: +44 330 053 3405, US: +1 (619) 391 9229.

To opt-out of the sale of your Personal Data, please click “Do Not Sell Or Share My Info” at the bottom of this page. At this time, we do not sell or share Personal Data as that term is defined under the CCPA or CPRA.

Virginia and Colorado Residents’ Supplement

Residents of specific US states, including Virginia and Colorado, have certain rights around our collection, use, and sharing of their Personal Data. We do not sell your Personal Data and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. We may engage in “targeted advertising” as that term is defined in the CDPA. As of January 1, 2023 you have the right to opt-out of targeted advertising.

We collect various categories of Personal Data when you use the Service which we describe above in the California Consumer Privacy Act Statement, including identifiers, commercial information, internet or other electronic network or device activity information, and more. A more detailed description of the information we collect and how we use it is provided above in the “Information We Collect” and “How We Use Personal Data” sections above. The “How We Disclose Personal Data” section describes the categories of third parties with whom we share Personal Data, and what information may be shared under different circumstances. Our “Non-Discrimination”, “Changes to Our Privacy Statement” and “Contact Information” sections above also apply to Virginia and Colorado Residents.

Virginia and Colorado Residents’ Rights

If you are a resident of Virginia or Colorado, you have the right to the following:

Right to access and obtain. You may request that we confirm whether or not we have or currently are processing your Personal Data. If we have or currently are processing your Personal Data, you can see what data we have processed by submitting a request via email to [email protected], or calling SI +386 1 828 4998, UK: +44 330 053 3405, US: +1 (619) 391 9229.

Right to correct. You have the right to correct inaccuracies in your Personal Data, considering the nature of the Personal Data and the purposes of the processing of the Personal Data.

Right to delete. You have the right to delete Personal Data provided by or obtained about you.

Right to data portability. You have the right to obtain a copy of your Personal Data that you previously provided in a readily usable format, to the extent technically feasible.

Right to opt-out of certain processing. We work with other companies and businesses to deliver interest-based ads to you, which enable us to provide our Services and relevant offers to you. In working with other companies and businesses, we may disclose Personal Data in a way that is considered to be for the following purposes under the CDPA: (1) targeted advertising, (2) sale of Personal Data, or (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the customer. You can request to opt-out of the sharing of your Personal Data in this manner by clicking on the “Do Not Sell Or Share My Info” link here or elsewhere on our Website, where you will find instructions on opting out of the use of your Personal Data.

Right to appeal. If we decline to take action in any request that you submit in connection with the rights described above, you may ask that we reconsider our response by sending an email to [email protected].  You must ask us to reconsider our decision within 45 days after we sent you our decision.

Exercising Your Rights

To exercise your rights to know or delete described above, please submit a request by either:

• Calling us at:

     SI: +386 1 828 4998,

     UK: +44 330 053 3405,

     US: +1 (619) 391 9229.

• Emailing us at [email protected]

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative, which may include, but is not limited to, Personal Identifiers, government issued identification, usernames and passwords, or other Personal Data. You will also need to describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Our Response - Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at [email protected] or call us at: SI +386 1 828 4998, UK: +44 330 053 3405, US: +1 (619) 391 9229. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, 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 the contact associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.