Your California Privacy Rights
Categories of Information We Collect
We may 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 CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:
|A.||Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver’s license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a User’s interaction with a website, application or advertisement.||YES|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated User information.
- Information excluded from the CCPA’s scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We may obtain such personal information from the following categories of sources (with the specific categories of personal information indicated in parenthesis.
- Directly from our CA Users. For example, from online registration forms that our CA Users submit to us related to the products and/or services that we offer by and through the Site. (Category A, B, C and I)
- Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Category A, B, C, F and I)
- Directly and indirectly from activity on the Site. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners, such as Google®. (Category F)
- When our CA Users interact with us on our social media accounts, including commenting on and/or liking our posts. (Category F)
- Directly from CA Users via online registration forms that our CA Users submit to us in order to enter a promotion or sweepstakes featured on the Site. (Category A, B, C and I)
- From third-parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Category A, B, C and I)
- From third-party data brokers or aggregators. (Category A, B, C and I)
- From publicly availably sources, such as Internet search engines. (Category A, B, C and I)
Use of Personal Information
We may use or disclose the personal information that we collect (including the following specific items of personal information: (a) e-mail address; (b) full name; and (c) telephone number; for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis) to fulfill or meet the reason for which the information is provided, such as:
- To provide you with information, products or services that you request from us. (Category A, B, C, F and I)
- To create, maintain, customize and secure your account with us. (Category A, B, C and I)
- To enable you to enter a promotion featured on the Site. (Category A, B, C and I)
- To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Category A, B, C, F and I)
- To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Category A, B, C, F and I)
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms and Conditions. (Category A, B, C, F and I)
- To improve the Site and better present its contents to you. (Category A, B, C, F and I)
- For customer service purposes and to respond to inquiries from you. (Category A, B, C and I)
- For testing, research, analysis and product development. (Category A, B, C, F and I)
- As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Category A, B, C, F and I)
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Category A, B, C, F and I)
- As described to you when collecting your personal information or as otherwise set forth under applicable law. (Category A, B, C, F and I)
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Category A, B, C, F and I)
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.
Sharing Personal Information
Subject to your right to opt-out of such sharing, we may share your personal information with/to third parties for marketing purposes, as well as other business purposes. The specific items of personal information that we may share include: (a) e-mail address; (b) full name; and (c) telephone number. When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
CATEGORIES – A, B, I
In the preceding twelve (12) months, we have sold the following categories of personal information to third parties:
We may disclose your personal information for a business purpose to the following categories of third parties (Category A, B, C, F and I)
- Service providers. (Category A, B, C, F and I)
- Third parties who provide products and/or services eatured on the Site. (Category A, B, C, F and I)
- Third parties who purchase and/or license your personal information for marketing purposes, including: (a providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. (Category A, B, C, F and I)
- Third parties to whom you authorize us to disclose your personal information in connectin with the products and/or services that we provide to you. (Category A, B, C, F and I)
In the preceding twelve (12) months, we have not : (a) sold personal information (including (i) e-mail address; (ii) full name; or (iii) telephone number; to the third parties who purchase and/or license your personal information for marketing purposes.
In the preceding twelve (12) months, we have:
- Received 0 requests for access to specific information and to exercise data portability rights. We have complied with 0 of those requests (in whole or in part) and denied 0 requests. The median number of days within which we substantively responded to such requests was 0;
- Received 0 requests to delete personal information. We have complied with 0 of those requests (in whole or in part) and denied 0 requests. The median number of days within which we substantively responded to such requests was 0; and
- Received 0 requests to opt-out from the sale of personal information. We have complied with 0 of those requests (in whole or in part) and denied 0 requests. The median number of days within which we substantively responded to such requests was 0.
Your Rights and Choices
The CCPA provides California residents (CA Users) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we have shared that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech rights, ensure the right of another CA User to exercise their free speech rights or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability and Deletion Rights
To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by emailing us at: firstname.lastname@example.org.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information. Where you make a data deletion request, data portability request and/or information access request through an authorized agent, we will require that you or the authorized agent provide us with a valid written authorization executed by both parties, with the validity of such document determined by us in our reasonable, good faith discretion. Please submit such documentation to us by emailing us at: email@example.com
You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:
- Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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 that the personal information relates to you. Making a verifiable CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; and/or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to these Provisions
We reserve the right to amend these Provisions in our discretion and at any time. When we make changes to these Provisions, we will notify you by email or through a notice on the Site’s homepage.