Last Modified: December 24, 2019. For California Residents, California Privacy Rights.
California Shine The Light Law. For California Residents, California Privacy Rights.
California Consumer Privacy Protection Act
Categories Of Personal Information We Collect About You, Why And How
Categories Of Personal Information Collected:
Categories Of Sources from which We Collected Personal Information:
HOW WE SHARE AND DISCLOSE YOUR INFORMATION
CALIFORNIA CONSUMER PRIVACY RIGHTS AND CHOICES
|NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA SHINE THE LIGHT LAW
Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us at [email protected].
For all such requests, please indicate “CA Shine the Light” in the subject field of your request and include the name of the Service with respect to which you are requesting the information. You must also include your full name, street address, city, state, zip code and email address.
NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT
The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Resident”) and uses our Services. This notice supplements the information in the Privacy Notice. Certain terms used below have the meanings given to them in the CCPA.
The following sets forth the categories of information we collect and purposes for which we may use California Residents’ personal information:
CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU, WHY AND HOW
Summarized in the table below are the categories of personal information we may collect about you over the past twelve (12) months, depending on how you interact with us. The following table also describes how we collect and use such categories of information.
More details on the categories of personal information, the purposes for which we collected such information and the sources from which we obtain your personal information are outlined below, and otherwise set forth in the Information We Collect and Obtain and How We Use the Information We Obtain Sections of our Privacy Notice.
Categories of Personal Information Collected:
· Identifiers (such as your contact information (name, email address, postal address, phone number), or unique personal identifiers (wireless device ID, cookies, IP address, username, password) (“Identifiers”);
· Commercial information (such as transaction data, purchase history, or delivery information) (“Commercial Data”);
· Financial information (such as credit or debit card information, verification number, and expiration date) (“Financial Data”);
· Internet or other network or device activity (such as browsing history, browser type and language, operating system or app usage) (“Internet Data”);
· Geo-location information (such as city, state and zip code associated with your IP address or derived through Wi-Fi triangulation; and with your permission in accordance with your mobile device settings, precise geolocation information from GPS-based functionality on your mobile devices (“Geo-location Data”);
· Inference information about you (such as preferences, characteristics, and behaviors) (“Inference Data”);
· Profile data about you and any inferences drawn from the profile data (such as characteristics, behaviors, attitudes) (“Profile Data”);
· Information that identifies or can be reasonable associated with you (“Associated Data”);
Business or Commercial Purposes for which We Collected or Disclosed Personal Information:
· performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services (“Performing Services”);
· auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance (“Auditing”);
· short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction (“Short-term Use”);
· detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (“Data Security & Fraud Prevention”);
· debugging to identify and repair errors that impair existing intended functionality (“Repairs”);
· undertaking internal research for technological development and demonstration (“Research and Development”);
· undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us (“Quality and Safety”); and
· to advance the commercial or economic interests of the Company, such as by inducing another to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction (“Commercial Interests”).
Categories of Sources from which We Collected Personal Information:
· Directly from you (“You”);
· From other sources (such as Company affiliates and/or business partners; advertising providers; analytics providers; marketers; public data bases; consumer data resellers; social media networks, in accordance with your privacy preferences on such services; researchers; payment processors; and surveys)(“Affiliates and Partners”);
· Through your use of the Services (“Services Use”).
HOW WE SHARE AND DISCLOSE YOUR INFORMATION
We will share the personal information collected from and about you over the past twelve (12) months as discussed above for various business purposes. The chart below explains the categories of information that we may share with third parties and the categories of those parties.
CALIFORNIA CONSUMER PRIVACY RIGHTS AND CHOICES
California Residents may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:
The right to access and disclosure. You may have the right to request, twice during a twelve-month period, the following information about the personal information we have collected about you during the past 12 months:
· the categories and specific pieces of personal information we have collected about you;
· the categories of sources from which we collected the personal information;
· the business or commercial purpose for which we collected or sold the personal information;
· the categories of third parties with whom we shared the personal information; and
· the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
The right to deletion. You may have the right to request that we delete the personal information we have collected from you.
Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
How to exercise your access and deletion rights.
California residents may exercise their California privacy rights by submitting your request to email: [email protected].
For security purposes, we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, you may need to provide your name and email address. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, we may also need to ask you for additional information to verify your identity.
Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:
· Where you have requested the categories of personal information that we have collected about you, we will respond by email providing such categories.
· Where you have requested specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA. For instance, we may not disclose government ID or financial account number as such disclosure may create an unreasonable risk to your personal information, your account with us, or our business systems.
· Where you have requested that we delete personal information that we have collected from you, we will delete, deidentify or aggregate any information about you that is not necessary for the purposes indicated above. Certain information may be exempt from such requests under applicable law.
If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request. For California Residents, California Privacy Rights.
The right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
The right to opt-out of the sale of your personal information. You have the right to opt out of the sale of your personal information. California law broadly defines “sale” such that it may include allowing third parties to receive certain information, such as IP address and/or browsing behavior, to deliver targeted advertising.
If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps to verify both (1) the identity of the person seeking to exercise their rights as listed above and (2) that your agent has been authorized to make a request on your behalf by providing us with a copy of a signed written authorization or a copy of a power of attorney. For California Residents, California Privacy Rights.