CCPA Privacy Notice
[vc_row][vc_column][vc_column_text]This Privacy Notice for California Residents supplements the information contained in and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit an email request to the following and include the words “CALIFORNIA PRIVACY” in the subject line, and you must put the statement “Your California Privacy Rights” in the body of the request and state the name of our specific website with respect to which you are requesting the information as well as your name, street address, city, state, and zip code.
Information We Collect From California Consumers
We collect Personal Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly for indirectly, with a particular consumer, household, or device.
Within the last twelve (12) months, we have collected the following categories of Personal Information from consumers. Some of the categories may overlap with each other:
|A. Identifiers||A real name, postal address, unique personal or online identifier, Internet Protocol (IP) address, email address, telephone number||YES|
|B. Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e))||All of the Identifiers listed above, plus: Physical characteristics or description (namely, a profile photograph)||YES|
|C. Legally Protected Characteristics||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)||NO|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||YES|
|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.||YES|
|F. Internet or similar network activity||Browsing history, search history, information regarding a consumer’s interaction with a website, mobile application, or online advertisement||YES|
|G. Geolocation data||Physical location or movements||YES|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information||NO|
|I. Employment information||Professional or employment-related information||NO|
|J. Education information, defined as nonpublic personally identifiable information under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g and 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 of other categories of Personal Information||A profile created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||NO|
Personal Information does not include:
- Publicly available information that is lawfully made from federal, state, or local government records
- De-identified, anonymized, or aggregated consumer information
- Medical information or protected health information governed by California and federal health information privacy laws
- Clinical trial information subject to the Federal Policy for the Protection of Human Subjects (the Common Rule)
- Personal information regulated by the Fair Credit Reporting Act (FCRA)
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our Users. For example, from the information that you provide to us through our online forms, email, or other means
- Indirectly from activity on our Site. For example, from website usage details collected automatically.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order to use our services
- To provide you with information or services that you request from us
- To provide you with email alerts and other notices concerning our services, events or news that may be of interest to you
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us
- To improve our Sites and present the contents to you
- For testing, research, analysis and product/service development
- As necessary or appropriate to protect the rights, property or safety of us, our Users, or others
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
- As described to you when collecting your Personal Information or as otherwise set forth in the California Consumer Privacy Act
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred
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 notice.
We do not collect any other personally identifiable information.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter 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, we have disclosed the following categories of Personal Information to third parties for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories
Category D: Commercial information
Category F: Internet activity
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Our service providers
In the preceding twelve (12) months, we have not sold any Personal Information
Your Rights and Choices
The CCPA provides consumers who are California residents with specific rights regarding their Personal Information.
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 Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you
- The categories of sources for the Personal Information we collected about you
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal information we collected about you (also called a data portability request)
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of each category of recipient obtained; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
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. Once we receive and confirm your verifiable consumer 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 Personal Information is necessary for us or our service providers 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 (Cal. Penal Code § 1546 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
- 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 your rights of access, data portability, and/or deletion described above, please submit a verifiable consumer request to us by:
Only you or a person registered with the California Secretary of State that you authorize 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:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or your authorized representative.
- 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 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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), 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 12-month period immediately preceding our receipt of your verifiable 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 useable and should allow you to transmit the information from one entity to another entity.
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.
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.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.