The California Consumer Privacy Act or “CCPA”, the California Privacy Rights Act of 2020 or “CPRA" (Cal. Civ. Code § 1798.100 et seq.), and the Shine the Light law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. This section of the Privacy Statement applies to information collected online and offline through or in connection with our Site or other Services.
California Consumer Privacy Act
In the preceding 12 months, we have collected the categories of personal information set forth in the table below. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
| Category of Personal Information | Examples | Collected | Disclosed for a business purpose within the past 12 months? | Sold or Shared with Third Parties within the past 12 months? | Categories of Recipients |
|---|---|---|---|---|---|
| Identifiers | Name, alias, address, email address, IP address, account name, unique device ID, etc. | Yes | Yes | Yes | (1) Affiliates. (2) Vendors and service providers such as payment processing, web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. (3) Third parties, such as analytics and advertising providers. (4) Other companies, applications, individual at you request. |
| Personal Information listed in California Customer Records Statute (Cal. Civ. Code §1798.80(e)) [Note: Some personal information included in this category may overlap with other categories] | Name, signature, address, telephone number, state ID number, financial information, medical information, etc. | Yes | Yes | Yes | (1) Affiliates. (2) Vendors and service providers such as payment processing, web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. (3) Third parties, such as analytics and advertising providers. (4) Other companies, applications, individual at you request. |
| Protected classifications characteristics | Gender, age, marital status, etc. | Yes | Yes | No | (1) Affiliates. (2) Vendors and service providers such as payment processing, web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. |
| Commercial information | Information about Services purchased, obtained, or considered | Yes | Yes | No | (1) Affiliates. (2) Vendors and service providers such as payment processing, web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. |
| Biometric information | Facial recognition, sleep data, health data, fingerprint, etc. | No | No | No | Not applicable |
| Internet or other similar network, browsing, or search activity | Domain information, browsing activity, session information, cookie information | Yes | Yes | Yes | (1) Affiliates. (2) Vendors and service providers such as payment processing, web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. (3) Third parties, such as analytics and advertising providers. (4) Other companies, applications, individual at you request. |
| Geolocation information | Physical location or movements | Yes | No | No | (1) Affiliates. (2) Vendors and service providers such as payment processing, web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. |
| Sensory information | Audio, electronic, visual, thermal, olfactory, or similar information. | Yes | Yes | No | (1) Affiliates. (2) Vendors and service providers such as payment processing, web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. |
| Professional or employment-related information | Current or past job history or performance evaluations. | No | No | No | Not applicable |
| Non-publicly available educational information under the Family Educational Rights and Privacy act (FERPA) and related regulations | Education records directly related to a student maintained by an educational intuition 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 | No | No | Not applicable |
| Inferences drawn from other personal information to create consumer profiles. | Characteristics, interests, and trends | Yes | Yes | Yes | (1) Affiliates. (2) Vendors and service providers such as payment processing, web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. (3) Third parties, such as analytics and advertising providers. |
California Privacy Rights Act
CPRA has required us to disclose the collection of your sensitive personal information. In the preceding 12 months, we have collected the following categories of sensitive personal information set forth below and we have disclosed the following categories of sensitive personal information for business purposes to the following categories of recipients.
| Category of Personal Information | Examples | Collected | Disclosed for a business purpose within the past 12 months? | Sold or Shared with Third Parties within the past 12 months? | Categories of Recipients |
|---|---|---|---|---|---|
| Government Identifiers | Social security, driver's license, state identification card, or passport number | No | No | No | N/A |
| Complete account access credentials | User names, account numbers, or card numbers combined with required access/security code or password | No | No | No | N/A |
| Precise geolocation | - | No | No | No | N/A |
| Racial or ethnic origin | - | No | No | No | N/A |
| Religious or philosophical beliefs | - | No | No | No | N/A |
| Union membership | - | No | No | No | N/A |
| Genetic data | - | No | No | No | N/A |
| Mail, email or text message contents | The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication | No | No |
No | N/A |
| Unique identifying biometric information | - | No | No | No | N/A |
| Medical information | Health information (such as health related information, sex lift, or sexual orientation information) | No | No | No | N/A |
Under CCPA and CPRA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal information covered by certain sector-specific privacy law, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Do Not Sell or Share My Personal Information
We do not sell or share your personal information for money but we and our business partners use tracking technologies to help us to understand our customers and visitors to the Services, to enhance your online experience, and to customize our offerings in ways that may be deemed a “sale” or “sharing” of personal information under the CCPA and CPRA. This includes working with third parties such as ad networks that collect personal information via tracking technologies to personalize advertisements on and off our Services and to provide us with data collection, reporting, and ad response measurement. To the extent we or our partners use such technologies on the Services, we offer a “Do Not Sell or Share My Personal Information” opt-out button (“Cookies Settings”), as discussed in the Advertising and Analytics section above. If you elect to opt out, then we will notify third parties of your request.
We do not knowingly sell personal information about consumers under the age of 16.
Your Rights under the CCPA and CPRA
Subject to certain limitations, you have the right to:
- request to know more about the categories and specific pieces of personal information we collect, use, disclose, and sell,
- request deletion of your personal information,
- request to correct inaccuracies of your personal information,
- opt out of any “sales” or “sharing” of your personal information that may be occurring,
- limit the use and sharing of sensitive personal information
- opt out of automated decision-making
- request to have your personal information transmitted to another entities (“Data portability”), and
- not be discriminated against for exercising these rights.
The privacy rights request is subject to our being able to reasonably verify your identity and authority to make these requests. In order to verify your identity when you submit a request, we will ask you to provide two (2) or three (3) pieces of personal information to confirm in our records. For example, you will be asked to provide at least your name, address, email address and/or details of your recent interactions with us.
How to Submit a Request Under the CCPA or CPRA
If your Personal Information is subject to the CCPA or CPRA, you may make these requests by completing this Form or call us at +1 (855) 961 4511. You may also authorize someone to exercise these rights on your behalf. In order to do so, we require signed permission. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or equivalent document that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise your rights under the CCPA or CPRA.
If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. Once we have a copy of the valid signed authorization, your designated representative/authorized agent will be able to exercise these rights with respect to the account(s) listed on such authorization for the life of the account, unless there is a specified term or expiration date on the authorization form. Any information gathered as part of the verification process will be used for verification purposes only. Responses to verifiable consumer requests will be delivered through secure email, depending on your election when you submit such requests.
Authorized Agents
You may use an authorized agent to submit a rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. This verification process is not necessary if your authorized agent provides documentation reflecting that the authorized agent has power of attorney to act on your behalf under Cal. Prob. Code §§ 4121 to 413. If you are an authorized agent seeking to make a request, please contact us online by completing this Form or by phone at +1 (855) 961 4511.
California Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at +1 (855) 961 4511 or online by completing this Form.
Metrics
California law requires us to compile metrics for the previous calendar year regarding consumer requests and responses. Below are certain metrics for requests we received from all individual from California between January 1, 2022 and December 31, 2022.