Effective Date: December 30, 2019
1. Information We Collect
- Publicly available information from government records;
- Deidentified or aggregated consumer information; and
- Information excluded from the CCPA’s scope, like:
- 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 laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, our Site has collected the following categories of Personal Data from its Users within the last twelve (12) months:
|A. Identifiers.||First name, last name, unique personal identifier, online identifier, Internet Protocol address, email address, account name, company name, or other similar identifiers.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||First name, last name, unique personal identifier, online identifier, Internet Protocol address, email address, account name, company name, or other similar identifiers. Some Personal Data included in this category may overlap with Personal Data included in other categories.|
|C. Protected classification characteristics under California or federal law.||Age, sex.|
|D. Commercial information.||None.|
|E. Biometric information.||None.|
|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.||Extracted from IP address.|
|H. Sensory data.||None.|
|I. Professional or employment-related information.||None.|
|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)).||None.|
|K. Inferences drawn from other personal information.||None.|
We obtain the Personal Data listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Site through cookies or other tracking mechanisms.
Use of Personal Data
Sharing Personal Data
2. Your Rights and Choices
The CCPA provides California residents with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and confirm your verifiable consumer request, to the extent it is possible to associate your request with any Personal Data that we possess, we will disclose to you:
- The categories of Personal Data we collected about you;
- The categories of sources for the Personal Data we collected about you;
- Our business or commercial purpose for collecting or selling that Personal Data;
- The categories of third parties with whom we share that Personal Data. The specific pieces of Personal Data we collected about you (also called a data portability request);
- The specific pieces of Personal Data we collected about you (also called a data portability request); and
- If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing: (i) sales, identifying the Personal Data categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, to the extent it is possible to associate your request with any Personal Data that we possess, we will delete (and direct our service providers to delete) your Personal Data 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 Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 (Cal. Penal Code § 1546 et. seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- 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.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at (917) 512-8915;
- Emailing us at firstname.lastname@example.org; or
- Sending us a message on the Site.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. 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:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.
We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity and/or authority to make the request.
Response Timing and Format
We try to respond to verifiable consumer requests within forty-five (45) days of receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the twelve (12) month period preceding receipt of the verifiable consumer 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 Data 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 a verifiable consumer request unless such a request 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.
Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Data at any time (the “right to opt-out”). We do not sell the Personal Data of Users we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Users who opt-in to Personal Data sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may email us at email@example.com or write us at 52 Walker Street, 5th Floor, New York, NY 10013.
We will only use Personal Data 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:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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 Data’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.
3. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits Users of our Site that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us at 52 Walker Street, 5th Floor, New York, NY 10013.
4. Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. When we amend this Notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of any such amendments.