The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:
- Specific pieces of Personal Information that we have collected about you;
- Categories of Personal Information that we have collected about you;
- Categories of sources from which the Personal Information was collected;
- Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
- Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
- The business or commercial purpose for collecting or, if applicable, selling Personal Information.
Collection of Personal Information
We currently collect and, in the 12 months prior to the Last Updated date of this Policy, have collected the following categories of Personal Information:
- Identifiers (name, postal address, online identifier, IP address, email address, account name)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number)
- Telephone number
- Internet or other electronic network activity information (browsing history; search history; and information regarding a consumer’s interaction with the Sites, application or advertisement)
- Geolocation data
- Commercial information (records of products or services purchased, obtained or considered)
- Professional or employment-related information (e.g., company name and role)
The Personal Information is collected from users directly and from internet service providers, data analytics providers, and operating systems and platforms. Not all categories of Personal Information are collected from each source.
In addition to the purposes stated above in the section “How We Use Your Information”, we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, and providing advertising, marketing, and analytic services
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of our services or products, and to improve, upgrade, or enhance same
- Commercial purposes, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, goods, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Disclosure or Sale of Personal Information
We do not sell personal information about you to outside parties. The following table identifies the categories of Personal Information that we disclosed for a business purpose to service providers in the prior 12 months and, for each category, the category of service providers or third parties to whom the Personal Information was disclosed or sold. We do not knowingly collect or sell the Personal Information of minors under 16 years of age.
|Category of Personal Information
|Category of Service Providers
|name, postal address, company name and role, email address, account name, telephone number
|online identifier, IP address, device identifier, cookies, beacons, pixel tags, mobile ad identifiers
|Data analytics providers
|browsing history, search history, and information regarding a consumer’s interaction with the website, application or advertisement; records of products or services purchased, obtained or considered; geolocation data
|Data analytics providers
Right to Request Deletion of Personal Information
You have the right to request that we delete the Personal Information about you that we have collected. However, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
How to Submit a Request to Know or Delete
You may submit a request to know or delete by emailing us at email@example.com
Our Process for Verifying a Request to Know or Delete
If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.
For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights
We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.”
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident, such as a signed writing from the consumer to the authorized agent and information proving that the consumer is a California resident.
We may at times provide consumers with a financial incentive, such as different pricing or services, for providing their personal information. When we do so, we feel that the value of the different pricing or services you will receive exceeds the cost of providing such personal information. You will always have an option whether or not to partake in such incentive programs.
Shine the Light Law
We do not disclose personal information obtained through our Sites to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.