The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes. We recognize the eleven (11) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, We have collected the following categories of personal information from 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, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|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.||YES|
|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).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|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 other 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. This information is gathered using the Consumer’s internet protocol address which Consumers provided directly to Us or automatically through their interaction with our products or services; licensors; service providers; and marketing partners.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||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|
|K. Inferences 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:
Any data that falls under one of the bullet points above will not be considered “personal information” under the CCPA.
We have obtained the categories of personal information listed above from the following categories of sources:
We may use this information to:
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 notice to You. Such notice may be delivered, for example, by posting an updated California Privacy Notice.
The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section or Web page.
The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
The right to delete Personal Data. Subject to certain exceptions, You have the right to request that we delete any of Your personal information that we collected from You and retained. If we receive and confirm Your consumer request as verifiable, unless an exception applies, we will delete (and direct our service providers to delete) Your personal information from our records.
The CCPA provides a number a reasons why a deletion request may be denied. We may deny Your deletion request if retaining the information is necessary for us or our service provider(s) to:
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:
In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can email, call us, or visit our "Do Not Sell My Personal Information" section.
Do Not Sell My Personal Information Requests
Eligibility and Verification of Requests
Only You or someone registered with the California Secretary of State and legally authorized to act on Your behalf may make a verifiable consumer request related to Your personal information.
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 that the personal information relates to You. Making a verifiable consumer request does not require You to create an account with us, but we must also be able to confirm the personal information relates to You. However, we do consider requests made through Your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of receiving it. If We require additional time to process Your request, up to a maximum total of ninety (90) days from the date the request is received, We will notify You of this and inform You of the reason for requiring the additional time.
If You have an online account with us, We will deliver our written response to Your online account. If You do not have an account with us, We will deliver our written response by mail or electronically, at Your option. 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 or have denied a request, if applicable.
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.
Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. When We make changes to this Notice, We will post the updated Notice on our website and update the Notice’s effective date. Your continued use of our website following the posting of changes constitutes Your acceptance of such changes.
If you have any questions about this California Consumer Privacy Act (“CCPA”), You can contact us:
Please print and retain a copy of this California Privacy Notice for your records.