Last Modified: December 19, 2019
ADDENDUM FOR CALIFORNIA RESIDENTS CALIFORNIA PRIVACY RIGHTS
NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT
In the below tables and sections, we describe (as required by the CCPA):
- Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,
- Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell Personal Information.
- Our Business Purposes – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
- Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.
The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:
Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
|Identifiers, e.g., name; alias; postal address; online identifiers; telephone numbers; IP address; mobile ad identifiers; email address; or similar identifiers.||Data compilers and consumer data resellers, informational and retail websites and service vendors, business-to-business companies, consumer surveys and survey companies. Advertising networks or platforms, operating systems and platforms and social networks. Government agencies such as the US Postal Service.|
|Characteristics of protected classifications under California or US law E.g., race; color; religion; sex/gender marital status; military or veteran status; national origin; ancestry.||Data compilers and consumer data resellers, informational and retail websites and service vendors.|
|Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. (This may include inferenced or self-reported information.)||Data compilers and consumer data resellers.|
|Internet or other electronic network activity information E.g., online interests.||Data compilers and consumer data resellers, informational and retail websites and service vendors, business-to-business companies, consumer surveys and survey companies. Advertising networks or platforms, operating systems and platforms and social networks.|
|Geolocation data||Government agencies such as the US Postal Services, and data analytics companies.|
|Professional or employment-related information E.g., occupation categories.||Data compilers and consumer data resellers, informational and retail websites and service vendors, business-to-business companies, consumer surveys and survey companies.|
|Inferenced Categories E.g., Inferenced consumer interests.||Data compilers and consumer data resellers.|
We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.
|Category||Categories of Third Parties We Share With|
|Identifiers, e.g., name; alias; postal address; online identifiers; telephone numbers; IP address; mobile ad identifiers; email address; or similar identifiers.||Data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, , content publishers, non-profit organizations, business-to-business companies, , financial institutions, telecommunications and internet service providers, hospitality industry providers, survey companies, other customers who provide goods and services to consumers advertising networks and platforms data analytics providers, health care analytics (referred to below together as “Customer Categories”).|
|Characteristics of protected classifications under California or US law E.g., race; color; religion; sex/gender marital status; military or veteran status; national origin; ancestry.||All Customer Categories.|
|Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. (This may include inferenced or self-reported information.)||All Customer Categories.|
|Internet or other electronic network activity information E.g., online interests.||All Customer Categories.|
|Geolocation data||All Customer Categories.|
|Professional or employment-related information. E.g., occupation categories.||All Customer Categories.|
|Inferenced Categories E.g., Inferenced consumer interests.||Data compilers and consumer data resellers.|
We also may share any of the personal information we collect as follows:
Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Sharing With Service Providers:We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.
Aggregated or Deidentified Information. We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
|Our Purposes for collecting, using and sharing Personal Information|
|Data marketing services, for example: providing marketing information to our Clients (which may include companies, non-profit organizations, other data compilers, resellers and platforms, advertising networks, and political organizations), generally regarding their marketing, fundraising, customer service and engagement, and outreach activities. helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs. assisting our Clients with use our Services to provide their consumers and prospects with better service, improved offerings, and special promotions, for instance, advising on which consumers or prospective consumers are most likely to be interested in certain offers.|
|Online targeting, for example: creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with prospective students). When we do this, we work with a data partner that “matches” our or other Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels. assisting Clients to create or use “identity” graphs, to help locate or resolve users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).|
|Additional marketing services, for example: assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing, including by providing insights.measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect or outdated information.|
|Operating our Services, for example: improving, testing, updating and verifying our own database.developing new products.operating, analyzing, improving, and securing our Services.|
|Other internal purposes, for example: For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We sometimes use the information collected from our own website from social networks, from other “business to business” interaction (such as at trade shows) or from data compilers for the above, as well as for our own marketing purposes.|
Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.) Please note that sometimes we act as a “service provider” for our clients, in which case we receive and act on instructions from the client(s) as to the client data provided: any requests to exercise rights with respect to data we handle on behalf of a client should be directed to the particular client.
a. Right to request access to your personal information
California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell. You may also request the specific pieces of personal information that we have collected from you. However, we may withhold some personal information where the risk to you or our business is too great to disclose the information.
b. Right to request deletion of your personal information
California residents may also request that we delete any personal information that we collected from you, such as if you have been a customer of ours. (Note that this is different from your right to “opt out” of us selling your personal information, which is described below; also note that we do not generally collect personal information directly from consumers.) However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
c. Right to “opt-out” of the sale of your personal information.
California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including making available a wide variety of information in exchange for “valuable consideration.”
Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section 2 of this Addendum.
If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information
d. How to exercise your access and (if applicable) deletion rights
California residents may exercise their California privacy rights by sending an email to email@example.com, submitting your request to here, or by contacting us at 800-730-3451.
For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.
Once we have verified your identity, we will respond to your request as appropriate:
- Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
- Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA and provided we do not believe there is an overriding privacy or security concern to doing so.
- Where you have requested that we delete personal information that we have collected from you, we will seek to confirm whether your request is for an “opt out” or a “deletion”: because “opt out” or “do not sell” rights enable us to maintain your information for “suppression” purposes – i.e., to prevent us from selling information about you in the future (which is what many consumers requesting “deletion” actually desire to occur) — we try to explain this in order to ensure we are meeting consumers’ preferences. (In addition, “deletion” rights only apply to information that we have collected “from” consumers – which does not apply to much of the information in our databases.)
- Upon completion of the above process, we will send you a notice that explains the categories of personal information we were able to locate about you, whether we (1) deleted, (2) deidentified, or (3) retained the information we collected from you. Certain information may be exempt from such requests under applicable law.
If we are unable to complete your requests fully for any of the reasons above, we will provide you with additional information about the reasons that we could not comply with your request.
e. Right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
f. Information About Persons Under 16 Years of Age
We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).
g. Authorized Agents
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.