FOR CALIFORNIA RESIDENTS

CALIFORNIA PRIVACY RIGHTS

Effective as of January 1, 2020

NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA SHINE THE LIGHT LAW

Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us.

For all such requests, please indicate "CA Shine the Light" in the subject field of your request and include the name of the Company Service with respect to which you are requesting the information. You must also include your full name, street address, city, state, and zip code.

 

NOTICE TO CALIFORNIA RESIDENTS  - CALIFORNIA CONSUMER PRIVACY PROTECTION ACT 

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. This notice supplements the information in the Privacy Notice.  Certain terms used below have the meanings given to them in the CCPA.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information by the Company:

 

CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU, WHY AND HOW

Summarized in the table below are the categories of personal information we may collect about you over the past twelve (12) months, depending on how you interact with us. The following table also describes how we collect and use such categories of information.

Categories of information collected Purposes of collection  Sources of personal information
Identifiers
  • Performing Services
  • Auditing
  • Short-term Use
  • Data Security & Fraud Prevention
  • Repairs
  • Research and Development
  • Quality and Safety
  • Commercial Interests

 

  • Services Use
  • Affiliates and Partners
  • You
Commercial Data
  • Performing Services
  • Short-term Use
  • Commercial Interests
  • Services Use
  • Affiliates and Partners
  • You

 

Financial Data
  • Performing Services

 

  • Services Use
  • Affiliates and Partners

 

Internet Data
  • Performing Services
  • Auditing
  • Short-term Use
  • Data Security & Fraud Prevention
  • Repairs
  • Research and Development
  • Quality and Safety
  • Commercial Interests

 

  • Services Use
  • You
Geo-location Data
  • Performing Services

 

  • Services Use

 

 

More details on the categories of personal information, the purposes for which we collected such information and the sources from which we obtain your personal information are outlined below, and otherwise set forth in the Information We Collect and Obtain and How We Use the Information We Obtain Sections of our Privacy Notice.

 

Categories of Personal Information Collected:

  • Identifiers (such as your contact information (name, email address, postal address, phone number), or unique personal identifiers (wireless device ID, cookies, IP address) (“Identifiers”);
  • Commercial information (such as transaction data, purchase history, or delivery information) (“Commercial Data”);
  • Financial information (such as credit or debit card information, verification number, and expiration date) (“Financial Data”);
  • Internet or other network or device activity (such as browsing history, browser type and language, operating system or app usage) (“Internet Data”); and
  • Geo-location information (such as city, state and zip code associated with your IP address or derived through Wi-Fi triangulation; and with your permission in accordance with your mobile device settings, precise geolocation information from GPS-based functionality on your mobile devices (“Geo-location Data”).

 

Business or Commercial Purposes for which We Collected or Disclosed Personal Information: 

  • performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services (“Performing Services”);
  • auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance (“Auditing”);
  • short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction (“Short-term Use”);
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (“Data Security & Fraud Prevention”);
  • debugging to identify and repair errors that impair existing intended functionality (“Repairs”);
  • undertaking internal research for technological development and demonstration (“Research and Development”);
  • undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us (“Quality and Safety”); and
  • to advance the commercial or economic interests of the Company, such as by inducing another to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction (“Commercial Interests”).

 

Categories of Sources from which We Collected Personal Information:

  • Directly from you (“You”);
  • From other sources (such as Company affiliates and/or business partners; advertising providers; analytics providers; marketers; public databases; consumer data resellers; social media networks, in accordance with your privacy preferences on such services; researchers; payment processors; and surveys)(“Affiliates and Partners”); and
  • Through your use of the Services (“Services Use”).

 

HOW WE SHARE AND DISCLOSE YOUR INFORMATION

We will share the personal information collected from and about you over the past twelve (12) months as discussed above for various business purposes.  The chart below explains the categories of information that we may share with third parties and the categories of those parties.

 

Third Parties with which we share information and why

 

Categories of information shared
Our Subsidiaries and Affiliated Businesses. We may share information we collect within our family of companies to deliver products and services to you, and enhance our products, services, and your customer experience, consistent with our Privacy Notice. Those businesses may also use your information for their own purposes, including marketing purposes.

 

  • All categories of information we collect may be shared with our affiliates
Third Party Partners for Marketing Purposes. We may share your information with partners whose offerings we think may interest you. For example, if you participate in sweepstakes, then we may share information with third parties for their marketing and other purposes.

 

  • Identifiers
  • Commercial Information
  • Internet Data
Third Party Partners to Provide Co-Branded Products and Services. In some cases, we may share information with third-party partners to provide co-branded products or services. For example, a co-sponsored sweepstakes or other promotion.

 

  • Identifiers
  • Commercial Information
  • Internet Data
Third Parties for Legal Requirements and Proceedings.  We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or government measures, and to comply with other legal obligations. We may disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.
  • Any or all categories of information may be shared with third parties for legal requirements and proceedings, depending on the specific legal requirements
Third Parties for the Protection of our Services and Users. We may disclose information to protect and defend the rights, interests, and safety of the Services, our subsidiaries and affiliates, and their employees, contractors and agents; to protect the security and safety of our users of the Services, including when we believe disclosure is necessary to prevent physical harm or financial loss.
  • Any or all categories of information may be shared with third parties for legal requirements and proceedings, depending on the specific legal requirements
Third Parties in Business Transfers.  We may disclose information in connection with a proposed or completed corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets.
  • Any or all categories of information may be shared with third parties in a business transaction, depending on the specific transaction
Third-Party Online Advertisers and Ad Networks.  As discussed in the Interest-Based Advertising Section of our Privacy Notice, the Services may rely on third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use, and these technologies will collect certain information from your use of the Services to assist in delivering such ads.
  • Identifiers
  • Internet Data
  • Geolocation Data

 

Internet Services Providers. In connection with the provision of the Services, we may share information with companies that provide internet services.
  • Identifiers
  • Internet Data
  • Geolocation Data

·

Data Analytics Providers.  We may share information with companies that provide data analytics services in order to operate, evaluate and improve our business.
  • Identifiers
  • Internet Data
  • Geolocation
Operating Systems and Platforms. We may share information with software companies that power your devices   and companies that provide common tools/ information for software or apps about software or app consumers.
  • Indentifiers
Social Networks. As discussed in the Information We Share Section of our Privay Notice, we may share your information with social networking services for their commercial marketing purposes.
  • Identifiers

 

 

CALIFORNIA CONSUMER PRIVACY RIGHTS AND CHOICES

California Consumers may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:

The right to access and disclosure.  You may have the right to request, twice during a twelve-month period, the following information about the personal information we have collected about you during the past 12 months:

  • the categories and specific pieces of personal information we have collected about you;
  • the categories of sources from which we collected the personal information;
  • the business or commercial purpose for which we collected or sold the personal information;
  • the categories of third parties with whom we shared the personal information; and
  • the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

 

The right to deletion. You may have the right to request that we delete the personal information we have collected from you.

Certain information may be exempt from such requests under applicable law.  We need certain types of information so that we can provide our Services to you.  If you ask us to delete it, you may no longer be able to access or use our Services.

 

How to exercise your access and deletion rights.

California residents may exercise their California privacy rights by  by sending an email to [email protected], or by contacting us at 1-800-277-3110.

For security purposes, we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights.  For instance, you may  need to provide your name and email address.. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, we may  need to ask you for additional information to verify your identity.

If you have an online account with us, logging into your account will serve to verify your identity and request, although we may request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, then we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:

  • Where you have requested the categories of personal information that we have collected about you, we will describe the type and format of the information disclosure.
  • Where you have requested specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA. For instance, we may not disclose government ID or financial account number as such disclosure may create an unreasonable risk to your personal information, your account with us, or our business systems
  • Where you have requested that we delete personal information that we have collected from you, we will delete, deidentify, or aggregate any information about you that is not necessary for the purposes indicated above. Certain information may be exempt from such requests under applicable law.

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

 

The right to nondiscriminationWe will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.  

 

The right to opt-out of the sale of your personal information. You have the right to opt out of the sale of your personal information. California law broadly defines sale such that it may include  allowing third parties to receive certain information, such as cookies, IP address and/or browsing behavior, to deliver targeted advertising.   

If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information

 

Authorized Agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney. 

 

HOW TO CONTACT US

If you are a California Consumer, to submit a request, please contact us at [email protected] or call us at 1-800-277-3110.  To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.