You can request to see certain data we have about you, or ask us to delete certain data we’ve collected from you. Please submit a privacy data request to request a copy of your data or to delete your data.
The State of California requires that we provide privacy information for individuals that are residents of California. If you are not a resident California, you can disregard this document.
1. Personal Information We Collect
1.1 Personal Information Does Note Include
1.2 Categories of Personal Information Collected
1.3 How We Obtain Your Personal Information
1.4 How We Use Your Personal Information
1.5 How Long We Retain Your Personal Information
1.6 How We Disclose Your Personal Information
1.7 Sale of Personal Information
1.8 Sharing of Personal Information
2. Your Rights Under the CCPA
2.1 Right to Know
2.2 Right to Delete
2.3 Right to Correct
2.4 Right to Limit the Use of Sensitive Personal Information
2.5 Right to Opt-Out
2.6 Right to Non-Discrimination
3. Submitting a Request to Know, Request to Delete, or Request to Correct
3.1 How to Submit a Request
3.2 Authorized Agents
3.3 Response Timing and Delivery Method
4. Social Media
5. Do Not Track Signals
7. How to Contact Us
Below is the legal information we are required to share:
1. PERSONAL INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”).
1.1 Personal Information Does Not Include
- Publicly available information from government records
- De-identified or aggregated consumer information
- Information excluded from the CPRA, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), and California Financial Information Privacy Act (FIPA).
AS A COURTESY, THE FOLLOWING DISCLOSURES INCLUDE INFORMATION THAT IS EXEMPT FROM CCPA. THE COURTESY DISCLOSURES ARE MADE WITH A RESERVATION OF ALL RIGHTS THAT WE HAVE UNDER CCPA.
1.2 Categories of Personal Information We Collect
In the last 12 months, we collected the following categories of personal information:
- "Sensitive Personal Information” such as Social Security numbers (SSNs), Driver’s license, financial account or card numbers, Precise geolocation, Racial and ethnic characteristics, Religious and philosophical beliefs, Union membership, Contents of mail, email and text messages, Genetic and biometric data.
- "Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
- "Other Personal Information” such as 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, or medical information. Some personal information included in this category may overlap with other categories;
- "Protected Classification Characteristics” such as age (40 years or older), date of birth, 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;
- "Commercial Information” such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- "Internet or Network Activity” such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement;
- "Geolocation Data” such as physical location or movements; and
- "Inferences” drawn from other personal information such as profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
1.3 How We Obtain Your Personal Information:
- Directly and indirectly from you based on activity on our website
- For example, from registration on our website, submissions on our website, or website usage details collected automatically
1.4 How We May Use Your Personal Information:
We may collect, use, disclose, or sell the personal information we collect for one or more of the following purposes:
1. Performing services on behalf of us, including maintaining or servicing accounts, providing customer service, providing the services and products available on our site, providing advertising or marketing services, or providing analytic services. This includes:
a. to fulfill or meet the reason for which the information is provided;
b. to provide you with information, products, or services that you request from us;
c. to provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you; and
d. to carry out our obligations and enforce our rights arising from any contracts entered into by us.
2. Undertaking internal research for technological development and demonstration.
3. Debugging to identify and repair errors that impair existing intended functionality.
4. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
5. Auditing related to a current interaction with a consumer or our customers, and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
6. Undertaking activities to verify or maintain the quality or safety or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the us.
7. For short-term, transient use, where the personal information is not disclosed to third parties to build a profile about consumers or to alter consumer’s online experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
8. To comply with our legal or regulatory obligations.
1.5 How Long We Retain Your Personal Information:
Absent contractual and/or legal requirements to the contrary, such as a legal hold, personal information is maintained for a specified period of time, as required by legal, regulatory, or industry requirements, as well as for business purposes.
- Sensitive Personal Information – 24 months.
- Identifiers – 6 years.
- Other Personal Information – 6 years.
- Protected Characteristics – 10 years.
- Commercial Information – 6 years.
- Internet or Network Activity – 6 years.
- Geolocation Data – 6 years.
- Inferences – 6 years.
1.6 How We May Disclose Your Personal Information:
We may disclose your personal information to a service provider, contractor, or third party. When we disclose personal information to a service provider or contractor, we enter into a written agreement that describes the purpose and requires the service provider to keep the personal information confidential and not use it for any purpose except performing the services described in the contract or as provided for in the CCPA. We disclose personal information to third parties as follows:
- Third parties:
- With advisors such as lawyers, banks, investors, and insurers, we share Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, and Inferences.
- With governmental and regulatory agencies, we share Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, and Inferences..
- With data analytics providers and website development tools, we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, and Inferences.
1.7 Sale of Personal Information:
We do not sell your personal information. We do not knowingly sell the personal information for California residents under the age of 16.
1.8 Sharing of Personal Information:
We do not share your personal information.
Our site is not intended for or directed to minors. We do not knowingly share the personal information of minors under 16 years of age.
2. YOUR RIGHTS UNDER THE CCPA
The CCPA provides California residents with specific rights regarding their personal information—the Right to Know, the Right to Delete, the Right to Correct, the Right to Opt-Out of the Sale of Personal Information or the Sharing of Personal Information, and the Right to Non-Discrimination. This section describes your CCPA rights and explains how to exercise those rights, if applicable.
2.1 Right to Know:
You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information (“Right to Know”). Once we receive and verify your request, we will disclose to you:
- Categories of Personal Information Collected, Disclosed, Sold, and/or Shared
- 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 that personal information.
- The categories of third parties with whom we share that personal information.
- If we disclosed your personal information to third parties, the corresponding categories of personal information.
- If we sold or shared your personal information for cross-contextual behavioral advertising, the categories of personal information sold or shared.
- Specific Information
- The specific pieces of personal information we collected about you.
2.2 Right to Delete:
You have the right to request that we delete your personal information (“Right to Delete”). Once we receive and verify your request, we will delete, de-identify, or aggregate your personal information, unless an exception applies.
We may deny your Request to Delete if retaining the personal information is necessary for us or our service providers to:
- complete the transaction for which the personal information was collected;
- to provide services or goods requested by a consumer;
- as reasonably expected within our ongoing relationship with consumers;
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- debug to identify and repair errors that impair existing intended functionality;
- exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
- short-term, transient use, if the personal information is not shared with a third party and is not used to build a customer profile;
- performing services on behalf of us or our service providers;
- internal use aligned with consumer expectations or the context in which the personal information was provided; or
- comply with legal or regulatory obligations.
2.3 Right to Correct:
You have the right to request that we correct your personal information if it is inaccurate (“Right to Correct”). Once we verify your identity and confirm that your personal information is inaccurate, we will correct your personal information.
2.4 Right to Limit the Use of Sensitive Personal Information:
You have the right to direct a business that collects your sensitive personal information to limit its use to uses which are necessary to perform the services or provide the goods reasonably expected. However, we only use Sensitive Personal Information to provide the goods and services requested by you; to prevent, detect, and investigate security incidents; to resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for such actions; to ensure people’s physical safety; to perform services on our behalf; to verify or maintain the quality or safety of our products, services, and devices.
2.5 Right to Opt-Out:
You have the right to opt-out of the sale of your personal information. However, as stated above, we do not sell your personal information.
You have the right to opt-out of the sharing of your personal information. However, as stated above, we do not share your personal information.
We do not process your personal information with automated decision making.
2.6 Right to Non-Discrimination:
You have the right to not be discriminated against for exercising your rights under the CCPA. Unless permitted by the CCPA, we will not:
- deny you goods or services;
- charge you higher prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- provide you a lower level or quality of goods or services; 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.
3. SUBMITTING A REQUEST TO KNOW, REQUEST TO DELETE, OR REQUEST TO CORRECT
3.1 How to submit a request:
Making a request does not require you to create an account with us. However, if you already have an existing online account, we will require you to log in to submit a request.
Only (1) you or (2) a person authorized by you to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We will need to verify your identity. Please provide your name and email address; and
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
3.2 Authorized Agents:
Before we can respond to a Request to Know, Request to Delete, or Request to Correct submitted by an authorized agent, we need to verify not only that person or entity’s authority to act on your behalf but also verify the identity of the authorized agent.
If you are authorized to submit a request on behalf of a California resident, please email us at email@example.com and provide the following information:
1. To verify your authorization to request on behalf of a California resident, please attach a copy of one or moreof the following to your request email:
- signed permission from the California resident, or
- a valid power of attorney
2. To verify your identity, please attach copies of the following to your request email:
- valid Government Issued ID (not expired)
3. To verify the identity of the consumer for whom you are submitting the request, please submit the required information by emailing us at firstname.lastname@example.org
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 the personal information relates to you. We will only use personal information provided in a request to verify the requestor's identity or authority to make the request.
3.3 Response Timing and Delivery Method:
We will acknowledge receipt of a Request to Know or Request to Delete within 10 business days and will respond within 45 days. If we require more time (up to 45 additional days for a total of 90 days from receipt of the request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your 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.
4. SOCIAL MEDIA
We encourage you to review your privacy options and settings with social media platforms and networks you use to understand what choices you have about disclosing your information through those platforms and networks with us.
5. DO NOT TRACK SIGNALS
Do Not Track is a web browser setting that requests websites and application to disable their tracking of an individual user. Our site does not respond to Do Not Track settings in your browser.
7. HOW TO CONTACT US
|Privacy Support Phone:||877-891-7869|
Privacy Support E-Mail:
Version 3.0 – Effective Date 01/6/2023