LAST MODIFIED: JANUARY 1, 2023
1. INFORMATION WE COLLECT
We may collect information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, in physical locations, through the mail, and/or over the telephone, that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer, household, or device.
“Personal Information” refers to any information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household.
“Sensitive Personal Information” includes social security number, passport number, financial account credentials, precise geolocation, racial, ethnic or religious information, personal communications, and genetic data.
Personal Information and Sensitive Personal Information does not include:
- Publicly available information (as defined under the CPRA).
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA and CPRA’s scope, like:
- 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”), clinical trial data, or other qualifying research data; and
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of Personal Information and Sensitive Personal Information from Consumers within the last twelve (12) months:
|A. Identifiers||A real name, alias, IP address, email address, or other similar identifiers.||YES|
|B. Personal information categories described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, 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, health insurance information, or account names.||YES|
|C. Protected classification characteristics under California or federal law.||Age, 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).||YES|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other electronic network activity information.||Browsing history, search history, login information, and IP addresses on the Company’s website, information systems and networks.||YES|
|G. Geolocation data.||Time and physical location related to use of an internet website, application, device, or physical access to a Company office location.||YES|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, call recordings or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history, including employer information, positions held, tenure with those employers, job performance, periods of unemployment or self-employment, and job responsibilities.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from any other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
We obtain the categories of Personal Information and Sensitive Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete on our website or services we provide you.
- Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website, among other things.
- Third parties. For example, we may receive information about you from our affiliates or other third parties we work with to provide you our products and services.
We retain your Personal Information and Sensitive Personal Information for as long as required to achieve its purpose or under any California or Federal law.
2. USE OF PERSONAL INFORMATION AND SENSITIVE PERSONAL INFORMATION
We may use, or disclose to third parties, the Personal Information and Sensitive Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the Personal Information and Sensitive Personal Information was provided to us by you. For example, if you share your name and contact information to request a price or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information and Sensitive Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide you with notices or announcements concerning our business operations, products, opportunities, or policies that may be relevant and/or of interest to you.
- To provide, support, personalize, and develop our website, services and products.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via e-mail or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our business processes, websites, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or government regulations.
- To maintain and protect the rights, property, security, and safety of you, consumers, clients, and others, as well as our facilities, premises, and other property.
- To support information technology services and detect and protect against security incidents and malicious, deceptive, fraudulent, or illegal activity, or violations of company policies or the law.
- 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 and Sensitive Personal Information held by us is among the assets transferred.
- As otherwise described to you when collecting your Personal Information and Sensitive Personal Information or as otherwise set forth in the CCPA and CPRA.
We will not collect additional categories of Personal Information and Sensitive Personal Information or use the Personal Information and Sensitive Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. DISCLOSING PERSONAL INFORMATION
We may disclose your Personal Information and Sensitive Personal Information to a third party for a business purpose. When we disclose Personal Information and Sensitive Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information and Sensitive Personal Information confidential and not use it for any purpose except performing the contract.
We disclose your Personal Information and Sensitive Personal Information with the following categories of third parties:
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your Personal Information and Sensitive Personal Information in connection with services we provide to you.
- Professional advisers, including law firms, accountants, auditors, and tax authorities.
- Affiliates, including parent or subsidiary organizations.
In the preceding twelve (12) months, we have disclosed the following categories (corresponding with the table above) of Personal Information and Sensitive Personal Information for a business purpose: Category A, Category B, Category C, Category D, Category F, Category G, Category I, Category K.
4. NO SALES OR Sharing OF PERSONAL INFORMATION and sensitive personal information
In the preceding twelve (12) months, we have not sold or shared any Personal Information or Sensitive Personal Information.
5. YOUR RIGHTS AND CHOICES
The CCPA and CPRA provide Consumers who are California residents with specific rights regarding their Personal Information and Sensitive Personal Information. This section describes your CPPA and CPRA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information and Sensitive Personal Information over the past 12 months (the “right to know”), unless responding to the request is impossible or involves disproportionate effort. Once we receive and confirm your verifiable request, we will disclose to you:
- The categories of Personal Information and Sensitive Personal Information we collected about you.
- The categories of sources for the Personal Information and Sensitive Personal Information we collected about you.
- Our business or commercial purpose for collecting, using and/or disclosing that information.
- The categories of third parties with whom we share, sell or disclose that Personal Information and Sensitive Personal Information.
- The specific pieces of Personal Information and Sensitive Personal Information we collected about you (also called a data portability request).
- If we disclosed your Personal Information and Sensitive Personal Information for a business purpose, a list of those disclosures, identifying the Personal Information and Sensitive Personal Information categories that each category of recipient obtained.
- Whether your information is sold or shared.
- The retention period or criteria used for retention.
Right to Delete and Correct
You have the right to request that we delete any of your Personal Information and Sensitive Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your Personal Information and Sensitive Personal Information from our 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 and Sensitive Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Help to ensure security and integrity to the extent the use of the Consumer’s Personal Information and Sensitive Personal Information is reasonably necessary and proportionate for those purpose.
- 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, ensure the right of another consumer 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 et. 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 Consumer 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.
In addition, you have the right to request that we correct any inaccurate Personal Information and Sensitive Personal Information about you that we collected (the “right to correct”). When applicable, once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct (and direct our service providers to correct) your Personal Information and Sensitive Personal Information, unless any lawful exception applies.
Exercising Your Rights to Know, Data Portability, Delete and Correct
To exercise your rights to know or delete described above, please submit a request either by:
- Emailing us at firstname.lastname@example.org and including “California Consumer Request to Know or Delete” in the subject line; or
- Submitting a CPRA Consumer Request Form. Please include the information listed on the form to confirm your identity.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information and Sensitive Personal Information. To designate an authorized agent, you must provide a valid power of attorney under California’s Probate Code or other verifiable written documentation granting the agent permission to make the request.
You may only submit a verifiable consumer request to know twice within a 12-month period. Each verifiable consumer request to know or delete must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information and/or Sensitive Personal Information or an authorized representative, which may include using the CPRA Consumer Request Form. You must provide at least two data points that we can match with the personal information we have collected about you.
- 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 and Sensitive Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information and Sensitive Personal Information relates to you. We will only use Personal Information or Sensitive Personal Information provided in a verifiable consumer request to confirm the requestor’s identity or authority to make the request.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through any password protected account, if available, sufficiently verified when the request relates to Personal Information and Sensitive Personal Information associated with that specific account.
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 send us a follow-up e-mail at email@example.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
If we offer consumer accounts and you have an account with us, we will deliver our written response to that account. If we do not offer consumer accounts, or 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 our receipt of the verifiable consumer 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, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly 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.
Personal Information and Sensitive Personal Information Sharing and Sales Opt-Out and Opt-In Rights
We do not sell or share any Personal Information or Sensitive Personal Information.
Right to Limit Sensitive Personal Information Use
You have the right to request us to limit the use or disclosure of certain Sensitive Personal Information we collected about you to uses necessary to provide you the services, and for certain business purposes (as listed in the CPRA). Please note that you may only object to the use and disclosure of a Sensitive Personal Information we collected or processed for the purpose of inferring characteristics about you.
You can send us a request to firstname.lastname@example.org. Once we receive and confirm your verifiable consumer request, we will limit the use or disclosure of your information (and direct our service providers to do so), unless any lawful exception applies. Please note that your request to limit the use or disclosure of Sensitive Personal Information shall not affect our right to request your consent to such use or disclosure again after twelve (12) months.
We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA, 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.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA and CPRA that can result in different prices, rates, or quality levels. Any CCPA and/or CPRA-permitted financial incentive we offer will reasonably relate to your Personal Information and Sensitive Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
6. OTHER CALIFORNIA PRIVACY RIGHTS
The Company does not generally engage third parties for direct marketing purposes. However, we provide notice here of California’s “Shine the Light” law (Civil Code Section § 1798.83) permits employees that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message via email@example.com.
7. Changes to our Privacy Notice for california CONSUMERs
We reserve the right to amend this Privacy Notice for California Consumers at our discretion and at any time. When we make changes to this Privacy Notice for California Consumers, we will post the updated notice on the website and update the notice’s effective date. You should review this Privacy Notice for California Consumers periodically to keep up to date on our most current policies and practices. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
8. Contact Information
If you have any questions or comments about this Privacy Notice for California Consumers, the ways in which Company collects and uses your information described here and in the Privacy Notice for California Consumers your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: (844) 922-2873
If you need to access this Privacy Notice for California Consumers in an alternative format due to having a disability, please send us an e-mail at firstname.lastname@example.org.