Effective Date: January 2020
This notice reflects our good faith understanding of the law and our data practices as of the date posted above, but the CCPA's implementing regulations are not yet final and there remain differing interpretations of the law. Accordingly, we may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.
PI We Collect and Disclose:
Sharing of PI:
We do not knowingly sell PI of minors under the age of 16.
If you are a California resident and this Notice applies to you, you can request from us:
- Categories: Up to twice in a twelve-month period, information regarding our practices with respect to your PI in the twelve months immediately prior to your request, including (i) the categories of PI collected, (ii) the categories of sources from which we collected the PI, (iii) the purposes for any collection or disclosure of the PI, (iv) the categories of third parties to whom we shared the PI, (v) a list of the categories of PI disclosed for a business purpose in the prior 12 months and the categories of recipients (or that no disclosure occurred); and (vi) confirmation that we have not sold PI as we understand the definition of sale under the CCPA;
- Specific pieces: Up to twice in a twelve-month period, access, via a transportable and (if technically feasible) readily usable form, to the PI maintained by us and collected about you in the 12 months immediately prior to your request; and
- That we delete your PI, which we will do unless there is a legal or other basis for which we must retain the PI under the CCPA (e.g., to complete transactions and services requested or reasonably anticipated, for security purposes, for legitimate internal business purposes and to maintain business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement). Note that we are not required to delete PI that we did not collect directly from you.
Please note that, in order to protect our customer's information, we will not disclose or delete information until we've confirmed the requester's identity as required by the CCPA.
Non-Discrimination and Financial Incentive Programs: We will not discriminate against you in a manner prohibited by applicable law for exercising your CCPA rights and choices.
Requests and Inquiries: Please submit requests and inquiries by calling 1-888-842-1115 or by emailing firstname.lastname@example.org. Please indicate in the request which right(s) you are exercising and provide us with an e-mail address or mailing address to which we can direct our response to your inquiry. Please note that, in order to protect our customer's information, requests will not be processed until the requester's identity is confirmed, and once we receive a request, we will verify it by requesting information sufficient to confirm the requester's identity. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent or where the requester's identity cannot be verified.