The California Consumer Privacy Act of 2018 (“CCPA”) provides verified California residents additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise these rights.
Notice of Collection
In the last twelve (12) months we have collected personal information in the following categories. The categories and examples provided in the chart below are defined in the CCPA. Not all information is collected about all individuals and it is possible that all examples of that category of Personal Information were not in fact collected but this reflects our belief that to the best of our knowledge that some of that information may have been collected about consumers. In response to a verified consumer request for categories of information collected, we will investigate and provide an individualized response to the consumer.
|Identifiers||A name, email address, IP Address, online identifier, or account name.|
|Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80)||A name, billing address, shipping address, telephone number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.|
|Protected classification characteristics under California or federal law||Age, veteran or military status.|
|Commercial information||Records of products purchased, obtained, or considered or other purchasing or consuming histories or tendencies.|
|Internet or similar network activity||Browsing history, search history, information on a consumer's interaction with a website, application or advertisement.|
|Geolocation data||Physical location.|
|Inferences drawn from personal information.||Profile reflecting a person's interests, preferences and favorites.|
Sources of Personal Information
We obtain the categories of Personal Information listed above from the following categories:
- Directly from you. For example, during account registrations or during purchases.
- Indirectly from you. For example, from observing actions on our Site.
- From third parties. For example, third party service providers who provide services or information for us.
Use and Disclosure of Personal Information
Under the CCPA “sale” means:
"(A) Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration; or (B) sharing orally, in writing, or by electronic or other means, a consumer's personal information with a third party, whether for valuable consideration or for no consideration, for the third party's commercial purposes." Accordingly, we do not sell our consumers personal information.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose Personal Information we collect for business or commercial purposes (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be comprehensive.
- Security. For example, preventing fraud, detecting security breaches, and maintaining the safety and security of our Site.
- Functionality debugging/error repair. For example, identifying and repairing errors in the functionality of the Site.
- Communications. For example, sending you offers, promotions, or notifying you about changes to our policies.
- Internal research and development. For example, research, analysis, and product development to improve our products.
- Performing Services. For example, creating, maintaining, and securing your account, processing your purchases, transactions, and payments.
- Quality and Safety Maintenance. For example, improving or enhancing our products or Site and verifying the quality and safety of our Site.
Disclosing Personal Information to Third Parties
We may disclose your personal information to the following categories for a business purpose or commercial purpose, as those are defined in the CCPA:
- Service providers
- Government regulators
- Advertisers and other third parties with whom we have business relationships
CCPA Privacy Rights
Under the CCPA, California residents have the specific rights regarding their Personal Information as described below.
(a) Right to Know about Personal Information Collected or “Sold”
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. After we receive and confirm your verifiable consumer request, we will disclose to you within the time required by the CCPA, the relevant information which may include:
- 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 specific pieces of Personal Information we collected about you.
- If we sold your Personal Information, or disclosed your Personal Information for a business purpose, two separate lists disclosing:
1. sales, identifying the Personal Information categories that each category of recipient purchased; and
2. disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
(b) Right to Delete
You have the right to request we delete any of your Personal Information we collected from you and retained, subject to exceptions, including if we need the Personal Information for a reason related to our business, such as
- Providing goods to you;
- Detecting and resolving issues related to security or functionality;
- Complying with legal obligations;
- Conducting research in public interest;
- Exercising free speech or ensuring another’s exercise of free speech; or
- Using the information for internal purposes that a consumer might reasonably expect.
After we receive and confirm a verifiable consumer request, we will delete the Personal Information from our records within the time required by the CCPA, unless an exception applies.
(c) Right to Non-Discrimination
You have the right not to receive discriminatory treatment for the exercise of any of your CCPA rights.
(d) Right to Opt-Out
You have the right to opt-out of the “sale” of your personal information. We do not currently sell personal information. If in the future that changes you will be notified and given the option to opt-out.Exercising Your Rights
To exercise your CCPA the rights, please submit a verifiable consumer request to us by emailing [email protected] or calling 888-425-6649. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person whom we collected personal information on or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or account sign-up authentication or other information needed to verify your identity. We cannot respond to the request or provide Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time, we will notify you of the need for a forty-five (45) day extension..