Effective Date: April 1, 2020
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include publicly available information, de-identified information, aggregate information, or any information protected by other privacy laws and otherwise excluded from the scope of the CCPA.
This table identifies the categories of personal information we have collected about consumers within the last 12 months:
Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
Personal information described in the California Customer Records statute (Cal. Civil 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.
Protected classification characteristics under California or federal law
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)
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Physiological, biological, or behavioral characteristics, including deoxyribonucleic acid (DNA), which can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Internet or other electronic network activity information
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
Physical location or movements
Audio, electronic, visual, thermal, olfactory, or similar information
Electronic recording of customer or prospective customer calls.
Professional or employment-related information
Current and prior job and salary history or performance evaluations.
Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 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.
Inferences drawn from any other category of personal information
Deriving information, data, assumptions, or conclusions from facts, evidence, or another source of information or data to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
How we Collect Personal Information
We obtain the personal information listed above from the following sources:
How We Use Your Information
We may use or disclose the personal information we collect for one or more of the following business or commercial purposes:
Sharing Personal Information
We may disclose your personal information for a business purpose to third parties, such as our subsidiaries and affiliates, as well as non-affiliated third-parties with whom we partner to offer products and services to you.
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose to the third parties identified above:
Sale of Personal Information
We may disclose certain information about you to consumer data resellers, advertising partners, affiliates, and other third parties for purposes that may be considered a “sale” under the CCPA. In the preceding 12 months, we have sold the following categories of personal information to third parties:
Your California Privacy Rights and Choices
If you are a California resident, the CCPA provides you with additional rights regarding our use of your personal information. This section describes your CCPA rights and explains how to exercise those rights.
(1) Right to Access Your Information
You have the right to request that we disclose certain information to you about our collection and use of your personal information during the 12-month period preceding your request. Once we receive and verify your request, we will disclose to you the information that you request and we are obligated to provide under the CCPA, which may include:
(2) Right to Request Deletion
You have the right to request that we delete some or all of the personal information that we have collected from you, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to whom we have furnished that information to also delete) your personal information from our (and their) records. With respect to the exceptions, we may deny your deletion request in whole or in part if retaining your personal information is necessary for us or our service providers to:
(3) Right to Opt-Out
You have the right to direct us not to sell your personal information to third parties. Any personal information about you that we sell to a third party cannot be sold by that third party unless you have received explicit notice and are provided with an opportunity to opt-out of the sale of your personal information.
You (or your authorized representative) may submit your request to opt-out by using the form available on this page.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, deletion and opt-out rights described above, please submit a verifiable consumer request to us by either:
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:
Generally, we will not request additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used for the purposes of verifying your identity and seeking to exercise your rights under the CCPA, and for security or fraud prevention purposes. We will delete any new personal information collected for the purposes of verification as soon as practical after processing your request, except as required to comply with the CCPA.
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 may require authentication that is reasonable in light of the nature of the personal information requested and will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Use of an Authorized Agent
If you use an authorized agent to submit a request to know or a request to delete, we may require that you provide the authorized agent written permission and require the authorized agent to verify its own identity with us.
A power of attorney to your authorized agent is an acceptable form of authorization.
We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
How we Verify your Request
When you submit a request to delete, or a request to know, we verify your request by taking the following steps:
When verifying a request, we consider the following factors:
When you request to know categories of personal information, we verify your identity to a reasonable degree of certainty.
When you request to delete, we verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm to you posed by unauthorized deletion.
In all cases, we verify by matching the identifying information provided with the request to the personal information of the consumer already maintained by us.
Response Timing and Format
Upon receiving a request to know or a request to delete, we will confirm receipt of the request within 15 days and provide information about how we will process the request.
We strive 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 preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For these 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 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.
(4) Right to Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. For example, we will not:
Please know that we may charge you a different price or rate or provide a different level or quality of goods or services if that difference is reasonably related to the value provided to you by your personal information.
Changes to Our Privacy Notice
Email: [email protected]