California Consumer Privacy

California-Specific Description of California Consumers’ Privacy Rights

This section of our privacy policy supplements the information contained in our general privacy policy. It applies only to all those who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act (CCPA) and other laws that provide rights specific to California residents.

Categories of Information We Collect

Our Services collect personal information. We have collected the following categories of personal information from our consumers within the last 12 months. The sources from which we obtain this information and the ways in which we use this information are set forth in our general privacy notice above. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Category: A. Identifiers.

• Examples: A 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.

• Collected: Yes

Category: B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

• Examples: 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. Some personal information included in this category may overlap with other categories.

• Collected: Yes

Category: C. Protected classification characteristics under California or federal law.

• Examples: 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).

• Collected: No

Category: D. Commercial information.

• Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Collected: Yes

Category: E. Biometric information.

• Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

• Collected: No

Category: F. Internet or other similar network activity.

• Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

• Collected: No

Category: G. Geolocation data.

• Examples: Physical location or movements.

• Collected: No

Category: H. Sensory data.

• Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

• Collected: No

Category: I. Professional or employment-related information.

• Examples: Current or past job history or performance evaluations.

• Collected: No

Category: J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

• Examples: 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.

• Collected: No

Category: K. Inferences drawn from other personal information.

• Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

• Collected: No

Disclosures of Personal Information for a Business Purpose

We disclose your personal information to third parties for business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Service providers, which we refer to as “vendors, consultants and other service providers” in our general privacy notice, above.

In the preceding 12 months, we have disclosed the following categories of personal information for business purposes:

• Category A: Identifiers.

• Category B: California Customer Records personal information categories.

• Category D: Commercial information.

Sales of Personal Information

In the preceding 12 months, we have not sold consumers’ personal information.

Your California Rights

The CCPA provides California consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Requests to Access to Specific Information

You have the right to request that we disclose information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see below), we will disclose to you:

• 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 categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you.

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• Sales (if any) along with the personal information categories that each category of recipient purchased; and

• Disclosures for a business purpose along with the personal information categories that each category of recipient obtained.

Deletion Requests

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will delete (and direct any of our service providers that hold your data on our behalf to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers as permitted by law.

Right to Opt-out of Sales of Personal Information

CCPA provides California consumers with the right to opt-out of the sale of their personal information. This right does not apply to our use of personal information because we do not sell personal information and have not sold personal information in the past 12 months.

Exercising Your Rights

To exercise the rights described above, please submit a request to us via email at [email protected].

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

You may only make a request for access or data portability twice within a 12-month period. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

• We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to requests within 30 days of its receipt, but we are allowed by law to take up to 45 days to respond. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your 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.

Verification

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:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Although we are permitted under CCPA to offer certain financial incentives that can result in different prices, rates, or quality levels, we do not presently do so.

This Privacy Policy was last updated on December 30, 2019.