California Consumer Privacy Statement
Effective date: January 1, 2020
1. Notice of Collection and Use of Personal Information
- Identifiers: Personally identifiable identifiers such as name, Social Security number, driver’s license number, passport number, billing address; telephone number and other forms of online identifier, internet protocol address, email address, account name, signature, bank account number, credit card number, debit card number and other similar identifiers.
- Technical Identifiers and Online Activity: Unique personal identifiers (such as a device identifier); cookies, beacons, pixel tags, mobile ad identifiers and similar technology Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
- Geolocation Data: Data approximated to region via an IP address.
- Inferred or Derived Information: Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.
2. Business Purposes:
In addition, we may use these categories of personal information for certain business purposes specified in the California Consumer Privacy Act, CCPA, as described below:
- Performing services, maintaining accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or similar 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;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
- Activities to verify or maintain the quality of service, the web site, a service or device that is owned, managed or controlled by us, and to improve, upgrade, or enhance the service
3. Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold for non-monetary consideration, and (d) the categories of personal information we may have disclosed for a business purpose.
a. Sources of Personal Information
We may have obtained personal information about you from various sources, as described below:
- Directly from you, such as when you create an account with us
- From your devices, such as when you visit our Sites
- Vendors who provide services on our behalf
- Joint marketing partners, our affiliates and online advertising services
- Social networks
b. Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below:
- Joint marketing partners, our affiliates, online advertising services and data analytics providers
- Vendors who provide services on our behalf
- Government entities
- Social networks
c. Sale of Personal Information
During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information:
- Identifiers such as a name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or identifiers), online identifier, internet protocol address, email address, and other similar identifiers
- Commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.
d. Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties for a business purpose the following categories of personal information:
- Commercial Information
- Technical Identifiers and Online Activity
- Geolocation Data
- Inferred or Derived Information
4. California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
- Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
- Deletion: You have the right to request that we delete certain personal information we have collected from you.
- Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an online account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an online account with us, and you request access to or deletion of your personal information, we may require you to provide any of the following information: a copy of your photo identification card or driver’s license or other identification to assist us in verifying your identity. In addition, if you do not have an online account and you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.