Effective Date: January 1, 2020
Last Reviewed: Dec 10, 2020
This Privacy Notice for California Residents applies to residents of the State of California following the California Consumer Privacy Act of 2018 (CCPA).
1. Information We Collect
“Personal information”, as defined by the CCPA, means “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.”
We’ve collected or not collected the following categories of personal information from California consumers 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, or other similar identifiers.||Yes|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, address, credit card number, debit card number, or any other financial information.||No|
|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|
|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 similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geolocation data.||Physical location or movements.||No|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history, responsibilities, memberships or performance evaluations, national identification information, travel-related records, background check and screening results, references, EEOC monitoring information (ethnicity, religion, gender and sexual orientation).||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 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|
|erences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’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) 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) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
• Directly from you.
• Indirectly from you. For example, from observing how you visit our website and how you move about when using it.
2. How We Use the Personal Information
We may use and disclose the personal information we collect from California residents for one or more of the following purposes:
• To process, respond to, and fulfill your request or inquiries.
• To create, maintain, customize, and secure your account with us.
• 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 email (with your consent, where required by law).
• To 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 website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• 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 about you is among the assets transferred.
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.
3. Sharing Personal Information
We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
We share your personal information with the following categories of third parties:
• Our affiliates
• Service providers
• Third parties such as ad networks.
4. Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
• Category A – Identifiers.
• Category D – Commercial information.
• Category F – Internet or other similar network activity.
We disclose your personal information for a business purpose to the following categories of third parties:
• Service providers. We disclose the categories of personal information to various vendors who provide us with services required to run our business.
5. Disclosures of Personal Information for a Commercial Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a commercial purpose:
• Category A – Identifiers.
We disclose your personal information for a commercial purpose to the following categories of third parties:
• Ad network who shows ads on this website that may entice you to make a purchase. In such a case, we are compensated for your traffic or transaction depending on the specific offering you click.
6. Sales of Personal Information
In the preceding twelve (12) months, we have sold the following categories of personal information:
• You may be tracked through our site by an ad network that identifies you through cookies or other identifiers for the purpose of showing you targeted advertisements. You may opt-out of this tracking by visiting the “Do Not Sell My Personal Information” link at the bottom of the website.
7. 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.
A. 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 12 months. Once we receive and confirm your verifiable consumer 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 share that personal information.
• The specific pieces of personal information we collected about you.
• 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.
B. 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 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.
- 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.
C. 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:
Emailing us at: [email protected]
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also designate a third party to exercise your rights – an authorized agent – however we will require written proof of the authorization and potentially proof of your identity.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• 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.
D. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
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.
8. Personal Information Sales Opt-Out and Opt-In Rights
You have the right to direct us to not sell your personal information at any time (the “right to opt-out”). Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, click the opt out link provided in the footer of this page (“Do Not Sell My Information”) and turn off “Sale of Personal Data”. You or your authorized agent can also send a request via email to us at [email protected]
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by contacting us and making the request.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the 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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
10. Changes to Our California Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and app as well as update the notice’s effective date. Your continued use of our website or mobile app following the posting of changes constitutes your acceptance of such changes.
11. Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at [email protected]