CCPA Privacy Notice
California Consumer Privacy Act
Notice for California Residents
[Last Updated: 04/10/2020]
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from or about consumers within the last twelve (12) months preceding the date of the last update of this CCPA Notice (the “Last Update”).
|Table I — Categories of Personal Information (w/examples)|
A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
|Categories of Personal Information Listed in 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.
Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
|Internet or other similar network activity|
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|Inferences drawn from other Personal Information|
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Information does not include:
- Publicly available information from government records
- De-identified or Aggregated Personal Information
- Information excluded from the CCPA including:
- Personal Information (health or medical information) covered by the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, or clinical trial data;
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, or the Driver’s Privacy Protection Act of 1994.
We obtain the Categories of Personal Information in Table I from the following Categories of Sources:
- Directly from Consumers. For example, from forms, surveys, responses, or other direct interactions from or with you, which you voluntarily provide to us.
|Categories of Sources|
|Identifiers||Directly from Consumer; Indirectly from Consumer|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Directly from Consumer|
|Commercial information.||Directly from Consumer, Indirectly from Consumer|
|Internet or other similar network activity||Indirectly from Consumer|
|Inferences drawn from other personal information.||Indirectly from Consumer|
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following commercial or business purposes (each a “Business Purpose”):
|Table III -Category of Personal Information||Business Purposes|
|Personal information categories listedin the California Customer Recordsstatute (Cal. Civ. Code § 1798.80(e)).||
|Internet or other similar network activity.||
|Inferences drawn from other personal information.||
We may also use or disclose any of the Categories of Personal Information set forth above for one or more of the following Business Purposes:
- to meet requirements imposed by law, including court orders, subpoenas, or compliance with the legal process;
- 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 permissible under the CCPA; and
- to evaluate or consummate 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 about users of our Websites 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 with notice and obtaining your explicit consent.
Sharing Personal Information
We may share your Personal Information with the following categories of recipients and third parties for business purposes:
- Service Providers
- Affiliate Partners
- Third Parties
|Table IV –Categories of|
|Categories of Recipients and Third Parties|
|Identifiers.||Service Providers; Affiliate Partners; Third Parties|
|Personal information categories listedin the California Customer Recordsstatute (Cal. Civ. Code § 1798.80(e)).||Service Providers|
|Commercial information.||Service Providers; Affiliate Partners|
|Internet or other similar network activity.||Service Providers|
|Inferences drawn from other personal information.||Service Providers|
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following Categories of Personal Information for a Business Purpose:
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Commercial activity.
- Internet or other similar network activity.
- Inferences drawn from other personal information.
Sales of Personal Information
Your Rights and Choices
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes such rights and explains how to exercise them.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your Personal Information. Once we receive and verify your request, we will disclose to you:
- The Categories of Personal Information we collected about you
- The Categories of Sources for the Personal Information that we collected about you
- Our Business 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:
- Categories of Personal Information that we sold about you and the categories of third parties to whom the Personal Information was sold; and
- Categories of Personal Information that we disclosed about you for a Business Purpose.
Deletion Request Rights
You have the right to request that we delete any of Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your 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 or 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 persecute those responsible for such activities
- Debug products that 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.
- 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 using our toll-free number at 1 (855) 636-7536
- Emailing us at [email protected]
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 an 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 related to you.
Making a verifiable consumer request does not require you to create an account with us. 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.
To submit a verifiable consumer request, the consumer may be required to provide additional information, which may include additional Personal Information, to enable us to verify the consumer’s identity with the degree of certainty required by the CCPA.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We or a third party on our behalf may follow up with you to determine whether a request is a verifiable consumer request under applicable law.
If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, we will deny the consumer request in whole or in part and will not to disclose the information requested or, as applicable, will not delete the information requested. We will respond to any such consumer request with a denial, and will also explain why it has no reasonable method by which it can verify the identity of the requestor.
However, if a consumer request that seeks disclosure of specific pieces of Personal Information is denied because we cannot verify the identity of the person making the request under the applicable verification rules under the CCPA, then we shall treat the request as one that seeks the disclosure of the categories of Personal Information and apply the verification rules in the CCPA applicable to requests for disclosure of categories of Personal Information.
Response Timing and Format
We will confirm receipt of a verifiable consumer request within then (10) days of its receipt.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) days of receipt of the request.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. If you do not have an account with us, and you do not indicate a preference for delivery, we will use its discretion in choosing the method of delivery of the information.
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, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this 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, including, but not limited to:
- Denying you products or services
- Charging you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of products or services
- Suggesting that you may receive a different price or rate for products or services or a different level or quality of products or services
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels, provided that: (i) the financial incentive is reasonably related to the value of your Personal Information and (ii) we provide you 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. See Notice on Financial Incentive section below.
Right to Designate an Authorized Agent
If you submit a request for access and portability or deletion through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.
Other California Privacy Rights
Pursuant to California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, including the names and addresses of those third parties, and examples of the types of Research Activities or products marketed by those third parties.
To make such a request, please send an email to [email protected].
Changes to Our CCPA Notice
This CCPA Notice is effective as of the ‘Effective Date’ date stated at the top of this CCPA Notice. We may change this CCPA Notice from time to time with or without notice to you. By visiting the Websites or accessing or using the Research Activities after we make any such changes to this CCPA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CCPA Notice in current effect. Please refer back to this CCPA Notice on a regular basis.
If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in the CCPA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: