CCPA COMPLIANCE
(DO NOT SELL MY DATA)

Last Updated: January 2026

INTRODUCTION

This page provides information for California residents about their rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

If you are a California resident, this page explains your privacy rights and how to exercise them.

SCOPE

This CCPA Compliance page applies to California residents whose personal information is processed by Xponential7 Ltd and its brands:

For our main privacy notice, see our Privacy Policy.

1. INFORMATION WE COLLECT

We collect the following categories of personal information from California residents:

Personal Identifiers

  • Name
  • Email address
  • Phone number
  • Company name
  • Job title
  • LinkedIn profile URL
  • IP address

Professional Information

  • Employment history (for career applications)
  • CV/resume
  • References
  • Work-related contact details

Internet Activity

  • Website usage data (pages visited, time on site, referral sources)
  • Device information (browser type, operating system)
  • Cookies and similar tracking technologies

Geolocation Data

  • General geographic location based on IP address (we do not collect precise location data)

Note: We do not collect sensitive personal information as defined by CCPA (e.g., Social Security numbers, driver's license numbers, precise geolocation, health data, financial account information).

2. HOW WE USE PERSONAL INFORMATION

We use the personal information we collect for the following business purposes:

  • Responding to enquiries: Processing contact form submissions and questions
  • Career applications: Evaluating candidates for employment
  • Marketing and communications: Sending relevant information about our services (with consent)
  • Analytics: Understanding website usage to improve user experience
  • Business operations: Managing client relationships, contracts, and operations
  • Legal compliance: Complying with applicable laws and regulations

For detailed information, see the "How We Use Your Data" section in our Privacy Policy.

3. SHARING PERSONAL INFORMATION

We may share your personal information with the following categories of third parties:

Service Providers
We share data with trusted service providers who assist us with:

  • Email delivery
  • Website analytics (Google Analytics)
  • Hosting and infrastructure
  • Customer relationship management (CRM)

These service providers are contractually obligated to process data only as instructed by us and to maintain appropriate security measures.

Business Clients (B2B Marketing Data Only)
For our Demand7 and GTM7 brands, we provide business contact information to our business clients for legitimate B2B marketing purposes. This activity may be considered a "sale" or "sharing" under CCPA.

Important distinction: This applies only to business contact data acquired from third-party sources (not data you submit directly through our website contact forms or career applications).
For details, see Section 7 "Distinction Between Website Visitor Data and B2B Marketing Data" in our Privacy Policy.

4. DO WE "SELL" OR "SHARE" PERSONAL INFORMATION?

Website Visitor Data: NO
We do NOT sell or share for cross-context behavioral advertising:

  • Contact form submissions
  • Newsletter subscriptions
  • Career applications
  • Cookie/analytics data

B2B Marketing Data: YES (Demand7 and GTM7 Only)
For our Demand7 and GTM7 lead generation services, we provide business contact information to our business clients. Under CCPA's broad definition of "sale", this may be considered a sale or sharing of personal information.

What this means:

  • We may acquire professional contact data from third-party data providers, commercial databases, and public sources
  • We enrich and validate this data
  • We provide this data to our business clients for B2B marketing purposes

This does NOT include:

  • Personal information you submit directly through our website contact forms
  • Career applications
  • Newsletter subscriptions

Legal basis: Legitimate business interests for B2B marketing (as permitted under CCPA's B2B exemption and GDPR Recital 47)

5. YOUR CALIFORNIA PRIVACY RIGHTS

California residents have the following rights under CCPA/CPRA:

1. RIGHT TO KNOW
You have the right to request information about the personal information we have collected, used, disclosed, and sold about you in the past 12 months.

What we will provide:

  • Categories of personal information collected
  • Categories of sources from which we collected it
  • Business or commercial purposes for collecting it
  • Categories of third parties with whom we shared it
  • Specific pieces of personal information we collected about you
  • If we sold or shared your personal information, categories sold/shared and to whom

How to request: Email privacy@xponential7.com with subject line "California Right to Know Request"
Response time: 45 days (may be extended by 45 days for complex requests)
Frequency: You can make this request twice in a 12-month period

2. RIGHT TO DELETE
You have the right to request deletion of personal information we have collected from you, subject to certain exceptions.

Exceptions: We may retain your data if necessary to:

  • Complete a transaction or provide a service you requested
  • Detect and resolve security incidents or fraud
  • Comply with legal obligations (e.g., tax records for 7 years)
  • Enable internal uses reasonably aligned with your expectations

How to request: Email privacy@xponential7.com with subject line "California Deletion Request"
Response time: 45 days (may be extended by 45 days for complex requests)

3. RIGHT TO CORRECT
You have the right to request that we correct inaccurate personal information we hold about you.
How to request: Email privacy@xponential7.com with subject line "California Correction Request" and include the correct information.
Response time: 45 days

4. RIGHT TO OPT-OUT OF SALE/SHARING
You have the right to opt out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising.

How to opt out:

For B2B Marketing Databases (Demand7/GTM7):
If your business contact information is in our Demand7 or GTM7 marketing databases and you wish to be removed:

  1. Email privacy@xponential7.com with subject line "B2B Data Opt-Out Request"
  2. Include your full name, email address, and company name
  3. We will process your request within 30 days and confirm removal

For Website Data:
If you visit our websites and do not want cookies/analytics data collected, decline cookies via our cookie consent banner.
Note: This opt-out applies only to the specific email address and device/browser you use. If you use multiple email addresses or devices, you will need to opt out separately for each.

5. RIGHT TO LIMIT USE OF SENSITIVE PERSONAL INFORMATION
We do not collect or use sensitive personal information (as defined by CPRA) in ways that would trigger this right.

6. RIGHT TO NON-DISCRIMINATION
You have the right to not receive discriminatory treatment for exercising any of your CCPA rights.
We will not:

  • Deny you goods or services
  • Charge you different prices or rates
  • Provide you a different level or quality of service
  • Suggest you will receive different pricing or service

6. HOW TO EXERCISE YOUR RIGHTS

To exercise your California privacy rights, contact us:

Email: privacy@xponential7.com
(Include the relevant subject line from the rights descriptions above)

Postal Address:
Xponential7 Ltd
Attn: Privacy Team
43 Tournay Road
London SW6 7UQ
United Kingdom

What to include in your request:

  • Your full name
  • Your email address
  • Your phone number
  • Your company name (if relevant to your request)
  • Description of your request
  • Confirmation that you are a California resident

Automated confirmation: When you submit a privacy request to privacy@xponential7.com, you will receive an automated confirmation email with a case reference number. We aim to respond to all requests within 45 days as required by California law.

Verification process:
To protect your privacy, we must verify your identity before processing your request. We verify requests by:

  1. Matching the email address you contact us from with our records
  2. Matching additional information you provide (name, phone number, company) with our database
  3. Requesting additional proof of identity if we cannot verify you from the information provided

Authorized agents:
You may designate an authorized agent to make a request on your behalf. The authorized agent must:

  • Provide proof of authorization (power of attorney or signed permission)
  • Verify their own identity
  • We may also require you to verify your identity directly with us

No fee: Exercising your CCPA rights is free.

7. CALIFORNIA "SHINE THE LIGHT" LAW

California Civil Code Section 1798.83 (California's "Shine the Light" law) permits California residents to request information about disclosures of personal information to third parties for direct marketing purposes.

Our position: We do not disclose Website Visitor Data (contact forms, career applications, newsletters) to third parties for their direct marketing purposes.

For B2B marketing data provided through Demand7/GTM7 services, see the "Do We Sell or Share Personal Information?" section above and opt out if desired.

8. CALIFORNIA MINORS

If you are a California resident under age 18 and have registered for any of our services, you have the right to request removal of content or information you posted.

How to request: Email privacy@xponential7.com with subject line "California Minor Content Removal Request"

Note: This does not ensure complete removal, as content may be retained in backups or republished by third parties.

9. UPDATES TO THIS PAGE

We may update this CCPA Compliance page from time to time to reflect changes in California law or our practices.

When we make changes:

  • The "Last Updated" date at the top of this page will be revised
  • If we make material changes, we will notify you by displaying a prominent notice on our website

We encourage you to review this page periodically.

10. CONTACT US

If you have questions about your California privacy rights, please contact us:

Email: privacy@xponential7.com

Postal Address:
Xponential7 Ltd
Attn: Privacy Team
43 Tournay Road
London SW6 7UQ
United Kingdom

11. RELATED POLICIES

For more information, please see: