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California Privacy Notice (CCPA)

This section provides additional information for California residents under the California Consumer Privacy Act (CCPA). The terms used in this section have the same meaning as in the CCPA. This section does not apply to information that is not considered “personal information,” such as anonymous, deidentified, or aggregated information, nor does it apply to publicly available information as defined in the CCPA.

Collection and Disclosure of Personal Information

The personal information we collect is described above in Information we collect. The personal information we disclose for business or commercial purposes is described above in How we share and disclose information. The length of time for which we retain personal information is described above in How long we keep your data.

Business and Commercial Purposes for Collection

We collect personal information for the following business purposes:

  • Advertising and Marketing
  • Audit Current Interactions
  • Error Management
  • Internal Research
  • Provide Products or Services
  • Quality Assurance
  • Security

We also “share” and “sell” (as defined in the CCPA) personal information for commercial purposes, including to advertise and market our products.

Information “Sharing” and “Selling”

We “share” certain personal information with third party ad networks for purposes of behavioral advertising, including: Internet Activity and Online Identifiers. This allows us to show you ads that are more relevant to you.

We use third party data analytics providers and this may be considered a “sale” of information under the CCPA.

Right to Know

You have the right to request to know the following about the personal information we have collected about you in the past 12 months:

  • the categories and specific pieces of personal information we have collected about you
  • the categories of sources from which we collect personal information about you
  • the business and commercial purposes for which we collect personal information
  • the categories of third parties with whom we share the information
  • the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose

If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.

Right to Delete

You have the right to request that we delete any personal information about you that you have provided to us. We will permanently delete from our records any personal information that is not necessary for our business operations and direct our service providers to do the same.

We consider information to be necessary for our business operations if it is used to:

  • Complete an obligation to you that you have requested
  • Detect and resolve issues related to security or functionality
  • Comply with legal obligations
  • Enable solely internal uses

Right to Non-Discrimination

If you exercise your CCPA consumer rights:

  • We will not deny goods or services to you
  • We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties
  • We will not provide a different level or quality of goods or services to you

Right to Opt-Out

You have the right to opt-out of any selling and sharing of your personal information.

Request Verification

Before we can respond to a Request to Know or Request to Delete, we will need to verify that you are the consumer who is the subject of the CCPA request. Verification is important for preventing fraudulent requests and identity theft. Requests to Opt-Out do not require verification.

Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your CCPA request.

For a request that seeks specific personal information, we ask that you sign a declaration stating that you are the consumer whose personal information is the subject of the request, as required by the CCPA.

In some cases, we may have no reasonable method by which we can verify a consumer’s identity. For example:

  • If a consumer submits a request but we have not collected any personal information about that consumer, we cannot verify the request.
  • If the only data we have collected about a consumer is gathered through website cookies (i.e. the consumer visited our website but had no other interaction with us), we are unable to reasonably associate a requester with any data collected; therefore, we cannot verify the request.

Authorized Agent

A California resident’s authorized agent may submit a Request to Know or a Request to Delete under the CCPA by emailing us at [email protected] Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.