Overview

This section applies only to California residents and supplements the information in our general Privacy Policy. For purposes of this Notice, “personal information” has the meaning given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). Personal information includes information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Personal Information Collected and the Purposes of Collection and Use

The list below summarizes the personal information we may collect, or have collected in the 12 months preceding the last updated date of this Policy, by reference to the categories specified in the CCPA. Examples in the list refer to the types of personal information described in our general Policy under the section titled “Information We Collect.”

  • Identifiers, such as Contact Information, Professional Information, Account Information, and Communications.
  • Customer Records, such as Account Information, Transaction History, Payment Information, and Communications.
  • Commercial Information, such as Transaction History and Marketing Information.
  • Internet or Network Activity, such as Online Activity Information and Device Information.
  • Geolocation Data, such as Device Information.
  • Audio, Electronic, Visual, or Similar Information, such as Communications and Survey Responses.
  • Professional or Employment-Related Information, such as Professional Information and Survey Responses.
  • Inferences, such as inferences drawn from the personal information identified above to create a profile reflecting your preferences, characteristics, behavior.

We may collect these categories of personal information directly from you and from your device, and from our service providers, advertising partners, and other third parties as further described in our general Policy under the section titled “Information We Collect.”

The purposes for which we collect and use these categories of personal information are described in our general Policy under the section titled “How We Use Personal Information.”

To the extent that we may collect sensitive personal information as defined under the CCPA, we only use or disclose it for purposes permitted under the CCPA (e.g., to perform the Services, detect security incidences and prevent fraud, and to verify and maintain the quality of the Services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.

Personal Information Disclosed for Business Purposes, “Sold,” or “Shared”

In the 12 months preceding the last updated date of this Policy, we may have disclosed each category of personal information listed above to the persons and entities listed in the section titled “How We Share Personal Information” for the business purposes described in our general Policy.

In addition, we may “sell” or “share” (and in the 12 months preceding the last updated date of this Policy have “sold” or “shared”) Internet or Network Activity to our Advertising Partners to help us market or advertise to you and to measure activity on the Services as further described under the section titled “How We Use Personal Information.” These disclosures are called “selling” or “sharing” under the CCPA because we are either disclosing your personal information in exchange for some sort of valuable consideration, or because such disclosure is for the purpose of cross-context behavioral advertising.

We do not knowingly “sell” or “share” the personal information of California residents under 18 years of age.‍

Retention of Personal Information

We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your California Privacy Rights

As a California resident, in addition to the choices described in the general Policy, you have the rights listed below. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

 Your Rights

  • Right to know. You can request the following information about how we have collected and used your personal information.
    • The categories of personal information we collected;
    • The categories of sources from which we collected that personal information;
    • Our business or commercial purpose for collecting, selling, or sharing (as applicable) that personal information; and
    • The categories of third parties to whom we disclose that personal information (as applicable).
  • Right to Access/Portability. You can request the specific pieces of personal information we collected about you.
  • Right to Correct. You can request that we correct inaccurate personal information that we maintain about you.
  • Right to Delete/Erase. You can request that we delete any of your personal information that we have collected from you.
  • Right to Opt-Out of “Sales”/“Sharing.” If we “sell” or “share” your personal information, you can request to opt-out.
  • Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.

How To Exercise Your Rights

You may exercise your California privacy rights described above using the following methods:

  • Right to Know, Access/Portability, Correct, or Delete. Please submit these requests using our Contact Form.
  • Right to Opt-Out of “Sale” or “Sharing.” To opt-out your personal information from “selling” and “sharing” relating to the automatic collection of data on our site by cookies and similar technologies, please submit a request using our Contact Form. Note that due to technological limitations, if you visit our site from a different computer or device, or if you clear cookies on your browser that stores your preferences, you may need to resubmit a request. Additionally, if you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shien the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

Confirmation of Identity

We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your right to know, access/portability, correct, and delete. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request.

Authorized Agent

Consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

We try to respond to all legitimate requests to know, access/portability, correct, and delete within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.