CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)
This section only applies to individual residents of California. The California Consumer Privacy Act (“CCPA”) gives California residents certain rights. This section covers our Collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA.
Capitalized terms defined in the CCPA that are used in this section shall have the same meaning as in the CCPA.
COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
Generally, we Collect, retain, use, and disclose your PI to provide you the services and as otherwise related to the operation of our business. In addition, we may Collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this section.
Information We Collect and Disclose
Identifiers: such as name, nickname, alias, contact information including email, phone number, and address, User ID, password, IP address, device ID, and account name and number
Business Purpose Disclosures: Service Providers, such as cloud vendors, analytics companies, social media networks, and advertising providers
Personal Records: such as financial account information
Business Purpose Disclosures: Service Providers, such as cloud vendors and financial services companies
Personal Characteristics and Traits: such as age and gender
Business Purpose Disclosures:Service Providers such ascloud vendors,analytics companies, advertising providers, and social media networksCustomer Account Details / Commercial Information: such as purchase or service history
Business Purpose Disclosures: Service Providers such as analytics companies, advertising providers, cloud vendors, financial services companies, and social media networks
Internet Usage Information: such as browsing history, referring URLs, search history, interactions with advertising links
Business Purpose Disclosures: Service Providers such as cloud providers, analytics companies, advertising providers, and social media networks
Geolocation Data: such as your location we infer based on your IP address
Business Purpose Disclosures: Service Providers such as analytics companies, advertising providers, and social media networks
Sensory Data: such as voice recordings from call centers
Business Purpose Disclosures: Service Providers such as customer service providers
Inferences from PI Collected: such as customer profiles, including customer characteristics and behaviors
Business Purpose Disclosures: Service Providers such as analytics companies, advertising providers, and social media network.
We do not knowingly Sell the PI of Consumers under 16. Any California residents under the age of 18 who have registered to use the services and who posted content or information.
We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.
Rights to Know and Delete Personal Information
California Consumers have the right to exercise certain privacy rights under the CCPA. California Consumers may also exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we Collected PI.
If you are unable to provide us with certain information about yourself and your interactions with us we will be unable to verify your identity to fulfill a request to know or delete. In some cases, we may verify your identity by confirming that you are the owner of the email address we have on file. For your specific pieces of information, as required by the CCPA, we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above.
Some PI we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s PI (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that Personal Information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we Collect, Process, store, disclose, and otherwise use and to respond to your California Consumer rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
You may use an authorized agent to submit a Consumer rights request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
The categories of PI we have Collected about you;
The categories of sources from which we Collected your PI;
The business or commercial purposes for our Collecting or Selling your PI;
The categories of third parties to whom we have disclosed your PI;
A list of the categories of PI disclosed for a Business Purpose in the prior 12 months, or that no disclosure occurred.
A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred. If we Sold your PI, we would explain the categories of your PI we have Sold and the categories of Third Parties to which we Sold PI, by categories of PI Sold for each Third Party.
b. Specific Pieces of PI
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have Collected, and are maintaining, in the period that is 12 months prior to the request date. Please note that we retain PI for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
c. The Right to Deletion
You may request that we delete your PI that we have Collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your PI for regulatory reasons, to complete a warranty or other contract with you, or for other internal uses of the information that are compatible with the context in which you provided it. Note also that we are not required to delete your PI that we did not Collect directly from you.
Notice of Financial Incentive and Non-Discrimination
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable PI. In addition, we may offer you financial incentives for the Collection, Sale, and retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive, if offered, will be explained and described in its program terms, as applicable. Please note that participating in incentive programs is entirely optional. You will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and applicable terms so check them regularly.
Notwithstanding anything to the contrary, we may Collect, use, and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
CALIFORNIA SHINE THE LIGHT LAW
California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of “personal information” (as defined by the “Shine the Light” law) to third parties for their own direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by email email@example.com
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