Information We Collect. We 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 Consumer or device (referred to collectively as “personal information”). In particular, We have collected the following categories of personal information from consumers within the last twelve (12) months:
- Identifiers which include for example, name, postal address, Internet Protocol address, email address, Social Security number, or driver’s license number.
- Personal information categories listed in the California Customer Records statute which include for example, name, contact information, education, employment, employment history and financial information.
- Protected classification characteristics under California or federal law which include for example, age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disabilities, gender, veteran status.
- Commercial information which includes for example, transaction information, purchase history, financial details and payment information.
- Internet or other similar network activity which includes for example, browsing history, search history, online behavior, interest data, and interactions with Our and other websites, applications, systems and advertisements.
- Geolocation data: Our applications do not collect precise geolocation data from GPS sensors. However, we do collect IP addresses from which we can determine your general location.
- Professional or employment-related information which includes for example, occupation, employer information.
- Non-public education information under the Family Educational Rights and Privacy Act which includes for example, education level, schools attended.
We collect this personal information listed directly from Our clients or their agents which includes for example, information Our clients provide to Us related to the Services for which they engage Us; directly from You which includes for example, information We ask from You when Our clients or their agents subscribe and engage Our Services; directly and indirectly from You when using Our Services or visiting Our website which includes for example, usage details collected automatically in the course of your interaction with Our platform or website.
Use of Personal Information
We may use this personal information to operate, manage, and maintain our business, to provide our products and services, to communicate with You, for our vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using personal information to: develop, improve, repair, and maintain our products and services; process or fulfill a request or other transactions submitted to us; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions; comply with law, legal process, and internal policies; maintain records; exercise and defend legal claims; and fulfill legal obligations.
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 notice.
We may disclose your personal information to a third party for a business purpose. When We disclose personal information for a business purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, We have disclosed the following categories of personal information for a business purpose to Our clients or their agents for which You have engaged in a business contract, Service providers, Third parties to whom You or your agents authorize Us to disclose your personal information in connection with Our Services:
- Category A: Identifiers.
- Category B: Personal information categories.
- Category C: Protected classification characteristics.
- Category D: Commercial information.
- Category E: Internet or other similar network activity.
- Category F: Geolocation data.
- Category G: Professional or employment-related information.
- Catagory H: Non-public education information.
In the preceding twelve (12) months, We have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) 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 to you (i) the categories of personal information We collected about You and the categories of sources from which We collected such information; (ii) the specific pieces of personal information We collected about You; (iii) the business or commercial purpose for collecting personal information about You; and (iv) the categories of personal information about You that We shared or disclosed and the categories of third parties with whom We shared or to whom We disclosed such information in the preceding 12 months. You also have the right to request that We delete personal information We collected from You subject to certain exceptions.
You also have the right to not be discriminated against in pricing and services because You exercise any of Your rights under the CCPA. We do not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.
Deletion Request Rights
You have the right to request that We delete any of your personal information We collected from You and retained, subject to certain exceptions. Once We receive and confirm your verifiable consumer request, We will delete (and direct Our service providers to delete) your 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, 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 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.
- Comply with the California Electronic Communications Privacy Act.
- 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.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Us by email 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 consumer request related to your personal information. You may also make a verifiable consumer 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.
- 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 the personal information relates to You. Making a verifiable consumer request does not require You to create an account with Us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If We require more time (up to 90 days), We will inform You of the reason and extension period in writing. If You have an account with Us, We will deliver Our written response to the registered email associated with the account. 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 the verifiable consumer request’s receipt. 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 usable 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 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.
We will not discriminate against You for exercising any of your CCPA rights. Unless permitted by the CCPA, We will not:
- Deny You use of Our Services.
- Provide You a different level or quality of Services.
Do Not Sell My Info
Effective January 1, 2020, California residents may opt out of the “sale” of their personal information. We sell certain of your information to third parties to provide you with offers and promotions and opportunities that may be of interest to you.
Under the CCPA, sale is defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.
Depending on what Services you use, we may provide the following categories of personal information to third parties for these purposes:
For online targeted advertising purposes: demographic and statistical information, user-generated content, device information and identifiers, browser and usage data, geolocation, and social media information.
For sharing with third parties to send you relevant offers, products, promotions and opportunities: contact and registration information, demographic and statistical information, employment and education data, user-generated content, device information and identifiers, and geolocation.
If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, you may exercise your opt-out choices by visiting our op-out page here. You can also submit a sale opt-out request by emailing us at email@example.com.
California law may require us to compile metrics for the previous calendar year regarding consumer requests and responses.
Changes to Our Privacy Notice
We will update this CCPA Notice from time to time. Any changes will be posted on this page with an updated revision date.
Last updated: Aug. 12 , 2020