Effective Date: April 22, 2021
Last Updated on: April 22, 2021
1. Consumer Rights. This section describes certain rights of Consumers under the California Consumer Privacy Act of 2018 (“CCPA”). For information on how Consumers may contact us to exercise these rights, please see “How to Submit a Request” below.
Right to Know. A Consumer has the right to request that a business disclose what personal information it collects, uses, discloses or sells. Specifically, a Consumer may request that a business that collects personal information about the Consumer disclose to the Consumer the following:
- The categories of personal information it has collected about that Consumer.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of non-affiliated entities with whom the business shares personal information.
- The specific pieces of personal information it has collected about that Consumer.
A Consumer may request that a business that sells the Consumer’s personal information, or that discloses it for a business purpose, disclose to that Consumer:
- The categories of personal information that the business collected about the Consumer.
- The categories of personal information that the business sold about the Consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- The categories of personal information that the business disclosed about the Consumer for a business purpose.
Right to Request Deletion. A Consumer has the right to request that a business delete any personal information about the Consumer which the business has collected from the Consumer. If it is necessary for us to maintain the personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.
Right to Opt-Out of Sale of Personal Information. We do not sell Consumers’ personal information. However, the collection of data through certain third-party cookies for our targeting advertising purposes may be considered a “sale” under the CCPA. While we do not sell Consumers’ personal information, we do use third-party cookies for targeted advertising purposes. To opt-out of having your information shared with third party digital advertising vendors for this purpose, please email us at firstname.lastname@example.org.
No Discrimination. A Consumer has the right not to be discriminated against because the Consumer exercised any of the Consumer’s rights under the CCPA.
How to Submit a Request. To exercise the rights described above, you must submit a verifiable Consumer request to us by contacting us at email@example.com and including “CCPA” in the subject line and detailing your request in the body. You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period. Your request must provide sufficient information to allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and it must describe your request with sufficient detail to allow 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.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
2. Information We Collect. We have collected the following categories of personal information from Consumers in the last twelve (12) months:
- Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
- Telephone number, education, employment status, credit card number, debit card number or other financial information.
- Characteristics of protected classifications under California or federal law (race, color, national origin, religion, gender, age (at least 40 years old)).
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an Internet Web site, application, or advertisement.
- Geolocation data.
- Inferences drawn from any personal information to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We collect the personal information described above from or through the following categories of sources:
- From you directly, including when you provide us with information over our website in our online forms or during in person surveying events;
- Indirectly from you, for example, from observing your actions on our website; and
- From service providers, including companies that provide analytics services to help us understand the activity on our website, and payment processors who process transaction purchased through our website.
- To provide our products and services to you and activities related to our provision of such products and 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, or providing analytics services;
- To fulfill orders purchased through the website and sending related communications;
- To improve, upgrade, or enhance our products and services;
- For employment purposes;
- To provide you with information about products and services that we may provide that we think may be of interest to you;
- To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; and
- To debug to identify and repair errors that impair existing functionality.
- Service providers to assist us in providing our products and services to you, including service providers that:
- host our databases, infrastructure and website;
- process payments of orders made through the our website;
- provide analytics services to help us understand the activity on our website;
- assist us with customer service;
- assist us with marketing and communications with our clients or potential clients; and
- assist us with the financial, regulatory and legal aspects of our business.
- Courts or governmental entities as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process.
- In connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part).
We have not sold personal information about Consumers in the twelve (12) months prior to the effective date of this policy.
We have disclosed personal information about Consumers to service providers for a business purpose in the twelve (12) months prior to the effective date of this policy.
5. Personal Information of Minors. We do not sell personal information of Consumers we actually know are less than 16 years old.