"We are Friends. Focused. About Media."
FFAM Group, LLC is a film and media production company that focus on creating quality projects that invoke emotion, humility, and humor to tell a story.
A Film Production and Media Consultant Company
We approach film projects using smart, creative strategies, financial resources and relationships to ensure completion as well as ownership stake.
Updated and effective December 29, 2022
INFORMATION WE MAY COLLECT THROUGH THE SITE
We may collect information from you directly, automatically when you visit the Site, and sometimes from third parties. Some of this information may be considered “personal information” under various applicable laws. We consider information that identifies you as a specific, identified individual to be personal information (such as your name or email address), and we treat additional information, such as IP addresses and cookie identifiers, as personal information where required by applicable law. If we combine non-personal information with personal information, we will treat the combined information as personal information. We may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function commonly known as a “hash”. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.
Information You Provide to the Site Directly
FFAM Group may ask you to provide information directly, such as contact information (e.g., name, email address or phone number), demographic information (e.g., ZIP code, gender or age), financial information (e.g., payment card information) and information about your interests and preferences. Some of this information is personal information. Where we ask you for personal information, we will tell you if it is optional. Otherwise, we are asking because it is necessary in order for us to provide you with the information or fulfill the transaction you requested.
The Site is not intended for persons under age sixteen (16). We do not knowingly collect personal information from children younger than the age of sixteen (16).
Community Forums, User Content, and Posting Content to Third-Party Sites
The Site may provide you the opportunity to participate and post content publicly in forums, through interactive features and through other communication functionality ("Community Forums"). You may choose, through such features or otherwise, to submit or post photographs, videos, questions, comments, suggestions or other content, (collectively, "User Content"). Please note that certain information, such as your name and state of residence, may be publicly displayed on the Site along with your User Content.
You acknowledge that if you choose to post any information publicly (such as on a third-party platform, in Social Media or in Community Forums) about your purchase, the content on the Site or your viewing history, the Video Privacy Protection Act of 1998 (18 U.S.C. § 2710) (the “VPPA”) (or any similar law) does not apply. However, to the extent the VPPA or any similar law does apply in any manner, you are providing your informed, written consent to the disclosure of that information pursuant to the VPPA and any similar law.
Send to a Friend Features
Information Third Parties Provide About You and Social Media Interactions
We may receive information about you from third parties. For example, if you are on another website and you agree to receive information from FFAM Group, that website will forward your information to us so that we may contact you. We also may supplement the information we collect with outside records from third parties, such as public databases, publicly available Social Media pages or joint marketing partners, for various purposes, such as to provide you with information, services or products, to tailor our content and the offers we show you, or to enhance our products and services.
The Site may permit or facilitate interactions with an interactive third-party website or service ("Social Media"), such as enabling you to “like” or “share” content. If you choose to share content or otherwise post information from or via the Site to Social Media, that information may be public and the third party may have access to information about you and your use of our Site. You may also choose to participate on Social Media in a way that connects that third-party service with our Site (such as posting to one of our pages on a Social Media site or signing into the Site with your credentials from another website or service). Doing so may allow us to collect (or the third party to share) information about you. We may also receive information about you if other users of Social Media give us access to their profiles and you are one of their “connections.” Note that through the Social Media features, these third parties may be able to collect certain information about your visits to the Site regardless of whether or not you affirmatively interact with the Social Media and whether or not you are logged into (or have) an account with the third party.
Information We Collect Automatically As You Access and Use the Site
In addition to any personal information or other information you choose to submit to the Site, we, and our third-party business partners (including without limitation third-party service providers, third-party advertising companies and content or analytics providers), may use a variety of technologies that automatically or passively collect certain website usage information whenever you visit or interact with the Site ("Site Usage Information"). This Site Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Site, the search terms you entered into a search engine that led you to our Site (if applicable), all of the areas within our Site that you visit, and the time of day, among other information. We may use this Site Usage Information for a variety of purposes, including without limitation enhancing or otherwise improving the Site. Site Usage Information is generally non-personal, but it may contain personal information, and if we associate it with your personal information, we will treat it as personal information. As you use the Site, we will also track the videos you watch (including without limitation which videos, how often you view the videos, and where you may pause or stop watching).
In addition, we automatically collect your IP address or other unique identifier ("Device Identifier") for your computer, mobile phone, or other device (any, a "Device") used to access the Site. We may be able to collect or infer your approximate location through information we collect, such as an IP address. A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our servers identify your Device by its Device Identifier.
Location Data. We may directly collect specific location information from your Device if you have opted-in to such collection through one of our applications. You may be able to turn off the collection of location information through your Device settings. However, please note that we may still be able to collect or infer your approximate location through other information we collect, such as IP address. In addition, some mobile service providers may also provide us or our third-party service providers or business partners with information regarding the physical location of the Device used to access the Site.
The methods used to collect Site Usage Information may include, without limitation, the following:
Cookies & Local Storage. A cookie is a data file placed on a Device when it is used to visit the Site or otherwise access our online content. Certain web browsers and certain browser add-ons may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Site may make use of this local storage. Cookies, and other local storage devices may be used for a variety of purposes (e.g., to identify your Device when you revisit our Site, to recall your authentication information, to store information related to your navigation throughout our Site, or to enable certain features on our Site). Some cookies are essential to the functioning of the Site, and, without them, some features and services you have requested cannot be provided. Other cookies help us to understand and improve how the Site works or allow us to personalize it for you. You may be able to refuse or remove some or all of these cookie and local storage technologies, such as through your browser settings. If you choose to do so, some features of the Site may not function properly. You can find more information about cookies and how they work at www.allaboutcookies.org.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “pixels”, "1x1 GIFs" or "clear GIFs") may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider or business partner, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
HOW WE MAY USE THE INFORMATION COLLECTED
FFAM Group may use information collected through the Site, including without limitation your personal information and Site Usage Information, as follows:
(1) in accordance with our legitimate interests, for example as is necessary for the following purposes: (a) to allow you to participate in the Site and features offered through the Site and to provide customer service, including without limitation to resolve any billing or payment processing inquiries; (b) to tailor content, recommendations, advertisements, and offers we display to you, both on the Site and elsewhere online (including without limitation keeping track of how and which videos you watch); (c) to send you emails with advertisements, promotions and other offers; (d) to use for internal business purposes such as to improve the Site or our products and services and for security and fraud prevention; (e) to process your registration with the Site, including without limitation verifying that your email address is active and valid; (f) to provide you with services or information or fulfill transactions that you have requested or otherwise agreed to receive, including without limitation authorizing and processing your payments and orders; (g) to contact you with regard to your use of the Site or similar administrative communications, including, without limitation and in our discretion, changes to the Site’s policies; (h) the purposes disclosed to you at the time you provided your information; or (i) to exercise our legal rights or defend ourselves from legal claims;
(2) to fulfill our contractual obligations to you, such as to make available content that you have purchased a subscription to view;
(3) to protect the vital interest of you or another person;
(4) to comply with regulatory and legal obligations;
(5) as necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or
(6) with your consent.
HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES
FFAM Group may share with third parties, in our discretion, non-personal information that does not identify you or relate to an identified or identifiable person, including certain Usage Information, information that has been hashed or otherwise de-identified, and aggregated user statistics – including for targeted advertising purposes. We do not share your personal information with third parties for those third parties’ marketing purposes unless we provide you the opportunity to opt-in or opt-out prior to such sharing, as required by applicable law. California residents, please see below for additional information in our "California Privacy Notice"
Third Parties Providing Services on Our Behalf. We sometimes use other businesses to perform services for us, such as website hosting, conducting website usage analysis, sending email or other communications, fulfilling orders, providing marketing assistance and data analysis, processing payments (including without limitation clearing and processing credit card payments), or performing other services. We may provide access to your personal information to such third parties in order for them to complete a requested transaction or otherwise to perform these services.
Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests or other promotions (any, a “Promotion”), that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, without limitation and except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law or permitted by the Promotion's terms or official rules (such as on a winners list).
Employment; EEOC. If you apply for a job with us via the Site, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity) in connection with laws and regulations enforced by the Equal Employment Opportunity Commission ("EEOC"), the Office of Federal Contract Compliance Programs ("OFCCP") and similar state and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information to the EEOC, the OFCCP and similar state and local regulatory agencies for business-related purposes, including, but not limited to responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
Business Transfers. In the event that FFAM Group goes through a transition such as being sold, has all or a portion of its assets acquired or transferred, whether voluntary or involuntary (such as through bankruptcy), or merges or becomes affiliated with any other division, individual or entity (including, without limitation, during the course of any due diligence process), any customer information owned or under the control of FFAM Group will likely be one of the transferred assets. We reserve the right, as part of this type of transaction, to assign or otherwise transfer your information and other information we have collected from users of the Site. By providing your personal information, you agree that we may transfer such information to the acquiring entity without your further consent.
THIRD-PARTY ADVERTISING COMPANIES AND ANALYTICS SERVICES AND SIMILAR THIRD PARTIES
These third parties may set and access their own tracking technologies on your Device (including without limitation cookies and web beacons) and may otherwise collect or have access to information about you (such as your Site Usage Information and Device Identifier), some of which may be considered personal information under various state laws. Some of these companies may collect personal information over time when you visit the Site or other online websites and services. Cookies and web beacons, including without limitation those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain information such as Device Identifiers, Site Usage Information and hashed or otherwise de-identified information with third-party advertising companies, analytics providers and other vendors for advertising and analytics purposes.
We use a variety of third parties to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). You may wish to visit optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members. You may also want to visit optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for participating companies. If you are a California resident, please see our “California Privacy Notice” for more information.
The European Digital Advertising Alliance (“EDAA”) has developed a guide to online behavioral advertising and has developed an opt-out page for participating EDAA member companies available at www.YourOnlineChoices.com.
For mobile apps, you may be able to limit certain advertising practices using the settings on your phone, tablet or other mobile device. You may download the AppChoices app at youradchoices.com/appchoices to opt out of the delivery of interest-based advertisements in mobile apps.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive non-targeted advertisements while online or on your Device.
HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Site does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser except as specifically required by law. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
CHANGING YOUR PREFERENCES AND ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION
The Site may contain web pages or features through which you can correct or update some of the personal information you have provided to us through registration through the Site. In addition, if you would like to review, correct, update, suppress, restrict or delete personal information that you have provided to us, you may contact us as set forth under “Contacting Us” below. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. FFAM Group will make good faith efforts to respond to your request as soon as reasonably practicable, consistent with applicable law. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or within our other records. Also, please note that we may need to retain certain information for our administrative or legal purposes. You are responsible for maintaining the accuracy of the information you submit to us.
If you access the Site through one of our mobile apps, we may, with your permission, send push notifications to your Device. You may opt-out of receiving these at any time by turning push notifications off in your Device settings.
Other Privacy Rights. If you are a California resident, please see our “Notices to California Residents” for additional information about how to exercise your privacy rights. If you are a Nevada resident, please see our “Notice to Nevada Residents” for more information on additional rights you may have.
Certain content on the Site may be hosted and served by third parties, and the Site may contain links to third-party websites that FFAM Group does not control. For example, our Site may provide links to third-party sites through which you can purchase merchandise, products or services or which link to a product or service offered by a third party. The Site may also contain certain third-party applications, such as email, web browser toolbars, wallpapers or other downloads or software applications. These links and applications may include, without limitation, those that use an FFAM Group logo as part of a co-branding agreement. In addition, FFAM Group widgets or other FFAM Group content may be included, among other places, on web pages and websites that are not associated with FFAM Group and over which we have no control. These third parties may collect Site Usage Information through the use of their own cookies and web beacons, independently collect data or solicit personal information, and may have the ability to track your use of their sites and services. FFAM Group is not responsible for the privacy or other practices employed by any third party.
While FFAM Group takes commercially reasonable steps designed to secure your personal information, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. FFAM Group cannot ensure or warrant the security of any information we collect. You use our Site and provide us information at your own risk.
JURISDICTION AND CROSS-BORDER TRANSFER
The Site is controlled and operated by FFAM Group from the United States of America. Visitors who use the Site and reside outside the United States of America do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable.
Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers or business partners, and, by using the Site, you consent to the transfer of information to countries outside of your country of residence, including without limitation the United States of America, which may have data protection rules that are different from those of your country. Personal Information processed or stored in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in accordance with the laws of that jurisdiction.
We keep personal information as long as needed for the purposes for which it was collected or for which you subsequently authorized it and additionally for as long as we are required to keep it because of legal obligations, professional accounting and audit standards, legal or insurance claims, or regulatory proceedings. Except as noted differently on specific pages or mobile apps, we retain your personal information while you have an account with us, or while you are using our app or continuing to visit us.
We ask that you not send us and not disclose any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sex life or sexual orientation, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Site or otherwise to us, unless we specifically request that information.
NOTICE TO NEVADA RESIDENTS
FFAM Group does not currently sell your covered information as those terms are defined under applicable Nevada law. However, you may still submit an opt-out request and we will honor that request as required by Nevada law if FFAM Group were ever to engage in such a sale in the future. If you are a Nevada resident and would like to opt-out of future sales of your covered information, please submit your request to email@example.com. Your request must include your full name, city, state and an email address so that we can contact you if needed regarding this request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and the authenticity of the request. FFAM Group will respond to your request within 60 days either confirming that your request has been processed or indicating that we need an additional 30 days to complete the request.
NOTICES TO CALIFORNIA RESIDENTS
California Privacy Notice (California Consumer Privacy Act)
This California Privacy Notice is effective April 20, 2022.
INFORMATION FFAM GROUP COLLECTS
Categories of Personal Information We Collect
We may collect some or all of the personal information described below. The personal information we collect about you will depend upon how you use our Site and other factors. In the past 12 months, the categories of personal information we may have collected from California residents are:
Notice to FFAM Group Employees, Contractors and Employment Applicants; Notice to Participants in FFAM Group Productions.
If you are an FFAM Group employee, contractor or employment applicant, or if you are a participant in an FFAM Group production. The Privacy Notice describes the information we collect about you, the purposes for which we collect it and additional information, and the Privacy Notice applies to information collected about you through the Site and to information collected about you offline.
Categories of Sources from Which We Collect Personal Information
We collect the personal information described above from the following sources:
Business and Commercial Purposes for Which We Collect Personal Information
We use the personal information described above for the following business and commercial purposes:
Categories of Third Parties to Whom We Share Personal Information
We share personal information with the following categories of third parties:
We may sell personal information to the following categories of third parties:
EXERCISING YOUR CALIFORNIA ACCESS, DELETION AND OPT OUT RIGHTS
California residents have the right to request information about what personal information we collect, use, disclose or sell, including without limitation the right to request that we provide to you the specific pieces of personal information we have collected about you over the past 12 months (“Request to Know”). California residents may also request that we delete their personal information we have collected (“Request to Delete”). California residents also have the right to opt out from the sale of their personal information. These rights are subject to some limitations, such as when we are retaining data to comply with our own legal obligations. More information on each of these rights is below.
If you are an agent submitting a request on a user’s behalf, please send an email to firstname.lastname@example.org with a declaration signed by the individual who is the subject of the request authorizing you to make the request on that individual’s behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. If we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
When you request access to the personal information we have collected or deletion of your personal information, we will typically provide the requested information within 45 days, and we will notify you within that time period if we need additional time to process your request.
How to Make a Request to Know or Request to Delete
If you are a California resident and would like to request information about the personal information we have collected about you in the prior 12 months or to request that we delete your information, please contact us at email@example.com or call us at (818) 835-3326.
To verify your identity, when you contact us with your request, please provide us your first and last name, the email address you have used to interact with FFAM Group, your mailing address, and your phone number. We may also request additional proof of identity (e.g., government identification) or other information as needed.
If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on the individual’s behalf), we will not be able to process the request.
Other Important Information
Request to Know
In order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Request to Delete
To ensure that we do not delete your personal information in response to a fraudulent request, once you submit the request, we may follow up to confirm that you want your information to be deleted.
RIGHT TO OPT-OUT OF THE SALE OF PERSONAL INFORMATION
The CCPA provides a right to California residents to request to opt-out of the sale of personal information. FFAM Group does not sell your personal information for monetary or other direct compensation. However, as indicated above, we may allow third-party advertising companies to collect data from visitors to our Site, including, without limitation, to serve you more relevant advertisements. These online advertising activities (and certain analytics or similar activities) may potentially be considered “sales” under the CCPA under certain circumstances.
Depending on the types of activities on the Site, FFAM Group may provide a tool to opt-out of certain cookies and other tracking technology. To opt-out of cookies and other tracking technologies set by FFAM Group and its third-party business partners that are potentially “sales” under the CCPA, you may use the opt-out tool, if any, available on the applicable FFAM Group website. In some cases we may provide an opt-out tool even where we are not sharing your personal information in exchange for valuable consideration.
Please read the "Third Party Advertising and Analytics and Similar Third Parties" section of the policy for more information on how you can manage your privacy via third parties. The Digital Advertising Alliance also offers tools for California consumers to send requests under the CCPA to opt out of the sale of personal information by some or all of the participating companies (https://www.privacyrights.info/).
Users Younger than 16
FFAM Group does not knowingly sell personal information of consumers younger than 16 years of age without affirmative authorization from the consumer (or, in the case of consumers younger than 13 years of age, the consumer’s parent or guardian).
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
California consumers have the right to not receive discriminatory treatment for exercising CCPA rights. We will not discriminate against you for exercising your CCPA rights.
Contact for More Information
For more information, you may contact us using the information in the “Contacting Us” section below.
Your California Privacy Rights (California Shine the Light Law)
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please contact us at firstname.lastname@example.org or FFAMGroup, LLC., Attn: Data Protection,141 S. A St., Oxnard, CA 93030. You must include the statement "Your California Privacy Rights" in the subject field of your communication to us and include your contact information in your communication to us.
Identifiers, such as name, address, IP address, email address and online identifier;
the categories of “personal information” described in California Civil Code Section 1798.80(e) including, without limitation, some of the identifiers previously listed;
characteristics of protected classifications under California or federal law, such as gender, veteran status and disability;
commercial information, such as products or services purchased and records of personal property;
internet or other electronic network activity information, including, but not limited to, information regarding your interaction with the Site;
audio, electronic, visual or similar information;
professional or employment-related information;
education information; and
inferences reflecting your preferences and characteristics and other information about you derived from the other categories of information above.
consumers’ use of the Site (through cookies and other tracking technology, for example);
our third-party business partners (such as data analytics providers, data brokers, advertising networks, co-producers and marketing partners, for example); and
third-party social media companies.
in accordance with our legitimate interests, for example as is necessary for the following purposes: (a) to allow you to participate in the Site and features offered through the Site and to provide customer service, including without limitation to resolve any billing or payment processing inquiries; (b) to tailor content, recommendations, advertisements, and offers we display to you, both on the Site and elsewhere online (including without limitation keeping track of how and which videos you watch); (c) to send you emails with advertisements, promotions and other offers; (d) to use for internal business purposes such as to improve the Site or our products and services and for security and fraud prevention; (e) to process your registration with the Site, including without limitation verifying that your email address is active and valid; (f) to provide you with services or information or fulfill transactions that you have requested or otherwise agreed to receive, including without limitation authorizing and processing your payments and orders; (g) to contact you with regard to your use of the Site or similar administrative communications, including, without limitation and in our discretion, changes to the Site’s policies; (h) the purposes disclosed to you at the time you provided your information; or (i) to exercise our legal rights or defend ourselves from legal claims;
to fulfill our contractual obligations to you, such as to make available content that you have purchased a subscription to view;
to protect the vital interest of you or another person;
to comply with regulatory and legal obligations;
as necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; and
for the purposes described to you when we obtain your consent.
our third-party service providers (third parties as needed to complete a transaction, third parties who assist with our information technology and security programs, and third parties who assist with loss and fraud prevention, for example);
our third-party business partners (such as data analytics providers, data brokers, advertising networks, co-producers and marketing partners, for example);
third-party social media companies;
third parties who provide professional services to FFAM Group;
law enforcement, government entities, or others if required by law (such as pursuant to
subpoenas or court orders);
companies that may or do acquire our assets, or companies that may or do lend us money;
other third parties when you agree to or direct that we share your information with them.
Third-party advertising, analytics and similar companies, including to better serve you more relevant and sometimes location-based advertisements, which may be considered a sale under CCPA under certain circumstances.