Personal Information Collected on California Consumers in the Last Twelve Months
Identifiers such as a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
Commercial information, including records of 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 (excluding real time GPS information).
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Our Use of Personal Information for Business Purposes in the Last Twelve Months
Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Debugging to identify and repair errors that impair existing intended functionality
Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
Sharing of Personal Information in the Last Twelve Months
Disclosures of Personal Information on California Consumers for Business Purposes:
Within the last twelve months, we have disclosed Personal Information identified in the above categories only (i) for exempt activities, as part of a business-to-business transaction, (ii) at your express request, or (iii) for our business purposes. For more information on the service providers with whom we share information, please see Our Disclosure of Your Personal Data and Other Information.
California Rights and Choices
Right to Know/Portability
You have the right to request that we disclose to you certain information about Personal Information we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:
the categories of Personal Information we have collected about you;
the categories of sources from which the Personal Information is collected;
our business or commercial purpose for collecting Personal Information;
the categories of third parties with whom we share Personal Information; and
the specific pieces of information we have collected about you.
Right to Opt Out
Right to Deletion
You have the right to request deletion of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we confirm your verifiable request, 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:
complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
debug products to identify and repair errors that impair existing intended functionality;
exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
comply with the California Electronic Communications Privacy Act;
enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
comply with a legal obligation; or
make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Non-Discrimination for Exercise of a California Privacy Rights
We will not discriminate against you because you exercise any of the above rights, or any other rights under the CCPA. Specifically, if you exercise your Rights, we will not deny you Services, charge you different prices or rates for Services or provide you a different level or quality of Services.
How to Submit A Request
You may submit a request to exercise the rights listed above by:
In your request, please include (1) full name used to create your account; (2) email with which you created your account; (3) phone number in case we need to contact you to securely verify your request; (4) whether you are requesting how your information is used and/or to delete your personal information.
As required under applicable law, we take steps to verify your identity before responding to your request. We may require you to provide information sufficient enough to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We may limit our response to your exercise of the above rights as permitted under applicable law.
Agent Authorization and Disability Access
You may designate an authorized agent to make a request on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent.
You may also make a verifiable consumer request on behalf of your minor child.
Right to Opt Out and Right to Opt In
Please note we do not sell Personal Information of California Consumers regardless of your age. If you are 16 years of age 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 know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to Personal Information sales may opt out of future sales at any time.
Responding to Requests
We will confirm receipt of your request within 10 days from receipt, and provide information about how we will process the request, our verification process, and when you can anticipate a response to the request.
We will use commercially reasonable efforts to honor your request within 45 days from receipt. If additional time is needed, we will notify you of the same, along with an explanation and anticipated timeline for the extension which shall not exceed 90 days from the date of receipt.
Other California Privacy Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Data which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request.