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Last Updated on October 23, 2020
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include
In particular, we collect the following categories of personal information from our consumers:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
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).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
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.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the categories of personal information listed above from general sources: Including, directly from you, for example, from forms you complete or products and services you purchase, as well as indirectly from you, from your devices and your actions on our Website.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
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 Policy.
Sharing Personal Information
We may share your personal information to a third party, such as service provider, for a business purpose, including but not limited to activities to maintain the quality of our products and services, and to enable purchases and to provide the information, product or services requested; auditing our products and services, to protect the security and integrity of systems, networks, applications and data, including detecting, analyzing and resolving security threats, debugging and fixing errors, research, subscription to newsletters, and other commercial transactions. When we disclose personal information for a business purpose, we enter into 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, Company has not disclosed personal information for a business purpose
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
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 (the “right to know”). Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will disclose to you:
Right to Delete
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 (“right to delete”). Once we receive your request and confirm your identity (see Exercising your Rights to Know or to Delete), 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 provider(s) to:
Exercising Your Rights to Know or to Delete
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
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 make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
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.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at email@example.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. 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 useable 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.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by sending us an email to firstname.lastname@example.org
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 in to personal information sales at any time.
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:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
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