LAST UPDATED: MARCH 4, 2021
For the purposes of the CCPA, we currently collect the categories of personal information listed in the chart below:
Business or Commercial Purposes: We use the categories of personal information listed above to provide our products and services to you, to operate, manage, and maintain our business, and to accomplish other business and commercial purposes, including the following:
Other Processing Activities: As permitted by applicable law, we may use all of the personal information that we collect in order to:
Additional Data Collection and Uses: We will not use your personal information for a purpose materially different than those disclosed in this notice at collection. If we seek to use personal information previously collected from you for a purpose materially different than what was previously disclosed to you in this notice at collection, we will directly notify you of this new use and obtain consent from you use it for this new purpose.
DATA PRACTICES DURING LAST 12 MONTHS
Personal Information Collected: As described in this policy, we have collected the categories of personal information listed below during the preceding 12 months:
Categories of Sources: The categories of sources from which we collect the personal information identified in this Policy are as follows:
Personal Information Disclosed for a Business Purpose. We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months:
We have disclosed each category of personal information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) investors; (4) service providers (data analytics, data storage, mailing, marketing, payment processing, website and platform administration, technical support; security monitoring); (5) operating systems and platforms; (6) advertising networks; (6) internet service providers; and (8) social networks.
Personal Information Sold: We do not sell your personal information and will not sell your personal information unless we modify this Policy and take additional steps as may be required under the CCPA.
In some instances, you may have the opportunity to provide personal information in exchange for a financial incentive or price or service difference. A “price or service difference” is (1) any difference in the price or rate charged for any goods or services to any consumer related to the collection, retention, or sale of personal information, including through the use of discounts, financial payments, or other benefits or penalties or (2) any difference in the level or quality of any goods or services offered to any consumer related to the collection, retention, or sale of personal information, including the denial of goods or services to the consumer.
Summary: The financial incentives we may provide to consumers are discount coupon codes or other price reductions, periodic promotional discounts and offers, and giveaways. These incentives involve the consumer providing following categories of personal information under the CCPA:
The financial incentive or price or service difference is reasonably related to the value provided by the consumer’s data, as data is required to facilitate the service. The value depends on how participating individuals interact with the service. We have obtained a good-faith estimate of the value of the consumer’s data that forms the basis for offering the financial incentive or price or service difference.
How to opt-in. You may choose to receive these financial incentives by opting-in on our Website and providing personal information when the option is presented to you.
How to withdraw. You have the right to withdraw from this service at any time. You may exercise that right by contacting us via the “Contact Us” details at the end of this Policy. If you opt-out, we will not reduce the value of any financial incentives you previously received from us.
The financial incentive or price or service difference is reasonably related to the value provided by the consumer’s data, as data is required to facilitate the service. The average estimated value of your data that forms the basis for offering the financial incentive is $49.31. The method to calculate this value takes into consideration, without limitation, the number of financial incentives offered, the number of orders placed using the financial incentive, the average dollar amount of each sale using the financial incentive, the redemption percentage of the financial incentive, and other relevant factors related to the estimated value of such information to our business as permitted under the CCPA.
DO NOT SELL MY PERSONAL INFORMATION
For the purposes of the CCPA, we do not sell your personal information to third parties. We will not sell your personal information unless we modify this Policy and take additional steps as may be required under the CCPA.
CCPA REQUESTS TO KNOW AND REQUESTS TO DELETE
The CCPA gives consumers the right to request that we (1) disclose what personal information we collect, use, disclose, and sell, and (2) delete certain personal information that we have collected or maintain. You may submit these requests to us as described below, and we honor these rights where they apply.
However, by way of example, these rights do not apply where we collect or sell a consumer’s personal information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s personal information occurred in California, and (3) no personal information collected while the consumer was in California is sold. In addition, de-identified information is not subject to these rights.
If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (1) treat the request as if it had been submitted in accordance with the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.
Request to Know
You have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold and the categories of third parties to whom the personal information was sold; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling personal information; and (7) the categories of third parties with whom we share personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request.
Submission Instructions. You may submit a request to know via our toll-free telephone number, 1-844-588-8783 or by email to firstname.lastname@example.org.
Verification Process. We are required by law to verify the identities of those who submit requests to know, and our verification process is described in detail below. We will inform you if we cannot verify your identity.
Response Process. Upon receiving a request to know, we will confirm receipt of the request within 10 business days and provide information about how we will process your request. The information provided will describe our verification process and when you should expect a response from us (unless we have already granted or denied the request). In general, we will respond to the request within 45 calendar days from the day we receive it; but, if necessary, we may take up to an additional 45 calendar days to respond to your request. If an extension is needed, we will notify you of the extension and explain the reasons that responding to your request will take more than 45 calendar days.
Once verification is complete, we will associate the information provided by you in the verifiable consumer request to any personal information previously collected by us about you. We will promptly take steps to disclose and deliver, free of charge to you, the information requested. We will provide an individualized response to requests regarding categories of personal information as required by applicable law; but, we may refer you to our general practices outlined in this Policy when our response would be the same for all consumers and all the information that is otherwise required to be in a response is presented here.
If you do not have a password-protected account with us, we may respond to a request to know related to household personal information by providing aggregate household information. If all consumers of a household jointly request access to specific pieces of personal information for the household, we will comply with the request if we can verify the identity of each consumer.
Delivery. Except as otherwise provided by applicable law, the information will be provided in writing and may be delivered through your account with us. If you do not maintain an account with us, we will respond by mail or electronically (at your option) in a portable and, to the extent technically feasible, readily-useable format that allows you to transmit the information to another entity. Alternatively, we may offer a secure self-service portal for consumers to access, view, and receive a portable copy of their personal information. If we do not take action on your request, we will, without delay and, at the latest, within the time period permitted for our response, inform you of the reasons that we did not take action and any rights you may have to appeal the decision.
Limitations. We are committed to responding to requests to know in accordance with applicable law. However, your rights are subject to the following limitations:
Denials. If we deny a verified request to know specific pieces of personal information, in whole or in part, because of a conflict with federal or state law, or an exception under applicable law, we will inform the requestor and explain the basis for the denial. If the request is denied only in part, we will disclose the other information sought by the consumer.
Request to Delete
You have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described below, we will delete your personal information from our records and direct any service providers (as defined under applicable law) to delete your personal information from their records.
Submission Instructions: You may submit a request to delete via our toll-free telephone number, 1-844-588-8783 or by email to email@example.com. We may present you with the choice to delete select portions of your personal information, but a global option to delete all personal information will be offered and more prominently presented.
Verification Process. We are required by law to verify the identities of those who submit requests to delete, and our verification process is described in detail below. We will inform you if we cannot verify your identity.
Response Process. Upon receiving a request to delete, we will confirm receipt of the request within 10 business days and provide information about how we will process your request. The information provided will describe our verification process and when you should expect a response from us (unless we have already granted or denied the request). We will use a two-step process for online requests to delete in which you must first, clearly submit the request to delete and then second, separately confirm that you want your personal information deleted. In general, we will respond to the request within 45 calendar days from the day we receive it; but, if necessary, we may take up to an additional 45 calendar days to respond to your request. If an extension is needed, we will notify you of the extension and explain the reasons that responding to your request will take more than 45 calendar days.
Once verification is complete, we will take one of the following actions: (1) permanently and completely erase the personal information on our existing systems (with the exception of archived or back-up systems); (2) de-identify the personal information; or (3) aggregate the consumer information. For personal information stored on archived or backup systems, we may delay compliance with your request to delete for that data until the archived or backup system relating to that data is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.
If you do not have a password-protected account with us, we may respond to a request to delete related to household personal information by providing aggregate household information. If all consumers of a household jointly request deletion for the household, we will comply with the request if we are able to verify the identity of each consumer.
Delivery. In our response to you, we will inform you of whether or not we have complied with your request. We will also inform you of our obligation to maintain a record of the request under California law.
Limitations. We are committed to responding to requests to delete in accordance with applicable law. However, we are not required to delete your personal information if it is necessary for us (or our service providers) to maintain your personal information in order to:
Denials. If we deny your request, we will (1) inform you that we will not comply with the request and describe the basis for the denial; (2) delete the personal information that is not subject to the exception; and (3) not use the personal information retained for any other purpose than provided for by the applicable exception(s).
To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your: (1) name; (2) shipping address; (3) billing address; (4) phone number; (5) email address; and (6) dollar amount of your most recent purchase from us.
If we cannot verify your identity based on the information already maintained, we may request additional information from you. We will try to limit the information collected, and we will only use this information to verify your identity and for security or fraud-prevention purposes. Except as required by law, we will delete any new personal information collected for the purposes of verification as soon as practical after processing the request.
We require different levels of authentication based upon the nature of the personal information requested. A more stringent verification process is applied when (1) sensitive or valuable personal information is involved, (2) there is a greater risk of harm to the consumer, and/or (3) there is a higher likelihood that fraudulent or malicious actors would request the information.
Password-Protected Account. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for the account. We will require you to re-authenticate yourself before disclosing or deleting your data. If we suspect fraudulent or malicious activity on or from the password-protected account, we will not comply with the request until further verification procedures determine that the request is authentic and that the consumer making the request is the person about whom we have collected information.
Request to Know Categories. For a request to know categories of personal information, we will verify the identity of the consumer making the request to a “reasonable degree of certainty” by matching at least two (2) data points provided by the consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the consumer.
Request to Know Specific Pieces. For a request to know specific pieces of personal information, we will verify the identity of the consumer making the request to a “reasonably high degree of certainty” by matching at least three (3) pieces of personal information provided by the consumer with personal information maintained by us, which we have determined to be reliable for the purpose of verifying the consumer, together with a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request. We are required by law to maintain all signed declarations as part of our record-keeping obligations.
Request to Delete. For a request to delete, we will verify the identity of the consumer to a “reasonable degree of certainty” or a “reasonably high degree of certainty,” depending on the sensitivity of the personal information and the risk of harm to the consumer posed by unauthorized deletion. For example, the deletion of family photographs and documents may require a reasonably high degree of certainty, while the deletion of browsing history may require a reasonable degree of certainty.
The CCPA allows you to use authorized agents to make requests on your behalf. If you use an authorized agent to submit a request to know or request to delete, we may require you to: (1) provide the authorized agent with written permission to do so; and (2) verify your identity directly with us. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code. We may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
In addition to the individual identity verification procedure described above, authorized agents will be required to submit the following written documentation:
Businesses: If the authorized agent is operating as a business, you must provide: (1) a certificate of good standing with your state of incorporation; (2) written authorization document that includes each customer’s name, address, telephone number, and valid email address, signed and dated by each consumer authorizing you, as the authorized agent, to act on behalf of each consumer in making the request; and (3) a valid email address for each consumer for our direct correspondence with each consumer, including an identity verification process to be conducted by us directly with that consumer.
Individuals: If the authorized agent is an individual, you must provide: (1) a “power of attorney” signed and dated by the consumer and notarized by a notary public naming you as the consumer’s authorized representative, which includes the consumer’s full name and physical California address and the consumer’s month/year of birth; (2) if you do not have a power of attorney signed by the consumer, then we require a written authorization document that includes the customer’s name, address, telephone number, and valid email address, signed by the consumer authorizing you, as the authorized agent, to act on behalf of the consumer in making the request; and (3) a valid email address for each consumer for our direct correspondence with each consumer, including an identity verification process to be conducted by us directly with that consumer.
If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.
You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the California Consumer Privacy Act. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers for exercising their rights under the CCPA.
CALIFORNIA SHINE THE LIGHT
Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting firstname.lastname@example.org.
UPDATES AND CHANGES TO THIS POLICY
We reserve the right, at any time and without notice, to add to, change, update, or modify this Policy to reflect any changes to the way in which we treat your personal information or in response to changes in law. Should this Policy change, we will post all changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will also notify you through a notice on the home page of the Site for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting on the Site. The date on which this policy was last modified is identified at the beginning of this Policy.
You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your personal information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, do not access, view, or use any part of the Site.
By Telephone: 1-844-588-8783
By Email: email@example.com