Definitions Specific to this Policy
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information obtained from government records; deidentified or aggregated consumer information that can not be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial InformationPrivacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.
“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party for monetary or other valuable consideration.
“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
“Third Party” means a person or entity who is not a business that collects Personal Information from consumers, as defined in the CCPA, and to whom the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
The Personal Information We Collect and Disclose
The chart below shows the categories of Personal Information we collect or may collect; examples of the type of Personal Information in each category; all types of sources from which each category of Personal Information is collected; the business purpose(s) for which that category of Personal Information is collected; and all types of third parties with whom that category of Personal Information is shared. As this chart shows, we disclose certain Personal Information to third parties for a business purpose. We also sell certain Personal Information to third parties. We do not sell the Personal Information of minors under 16 years old without affirmative authorization. This information covers the past 12months.
|Category of Personal Information||Examples:||Types of Sources from which this Category of Personal Information is Collected||Business Purpose(s) for Collecting, Disclosing, and Selling||Types of Third Parties with Whom this Category of Personal Information Is Sold and/or Disclosed|
|Unique Identifiers||Name, address, telephone email, account name, online identifier, IP address||The consumer directly; Marketing agencies (cookies, pixels, IP, etc.); Shipping partners; and Fulfillment partners||Customer support; Credit card processing; Digital Marketing; Social media advertising; Shipping/ order fulfillment; and Order processing||Sold: Data analytics tools; Digital Marketing; and Social media companies and users.|
Disclosure: Carriers and shipping partners; Ticketing Platforms; Email service providers; Customer service providers; and Payment providers.
|Financial Information||Credit card number, debit card number, or any other financial information||Directly from customers; Partners of the business; and Credit reporting agencies.||Complete payment transactions (with customers or partners); and Process returns.||Disclosure: Payment processors; Shipment and fulfillment providers; and Customer service providers.|
|Protected class data||Characteristics of protected classifications under California or federal law, including: race, ancestry, national origin, age (40 years or older), marital status, sex, sexual orientation, medical condition, disability, genetics, and veteran or military status||Directly from Customers; Credit report agencies; and social media companies.||Customer service; and To provide relevant digital marketing.||Disclosure: Marketing partners; and Customer service providers.|
|Purchase history||Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Directly from Customers; Credit reporting agencies; and Digital marketing.||Customer service; Experience management; and Digital marketing.||Sold: Analytics companies; Digital marketing; and Social media companies|
Disclosure: Payment processors; Shipping and fulfillment providers; and Customer service providers.
|Biometric data||Voice recordings||From Customer; and Our call center providers.||To record customer service calls.||Disclosure: Customer service providers.|
|Internet activity||Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement||Directly from customers; Social media companies and users; and Digital Marketing and analytics tools.||Customer support/experience; and Digital marketing and advertising.||Sold: Data analytics tools; Digital marketing; and Social media companies and users.|
Disclosure: Email providers
|Inferences||Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||The consumer directly; Digital marketing companies; Social media companies; Shipping partners; Fulfillment partners; and Credit reporting agencies.||Digital marketing companies; Marketing email providers; and Customer support/experience||Sold: Data analytics tools; Digital marketing; and Social media companies and users.|
Disclosure: Email providers.
We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.
You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements.
- If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of sources providing that Personal Information; (3) the categories of third parties with whom we have shared that Personal Information; and(4) the business purpose for collecting that Personal Information, click here or call 949-336-7500. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
- If you would like to request the specific pieces of Personal Information we collected about you, click here or call 949-336-7500. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request
- If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of Personal Information sold; (3) the categories of third parties to whom the information was sold; and (4) the categories of Personal Information that were disclosed for a business purpose, click here or call 949-336-7500. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
In order to protect your information, we will confirm a requestor’s identity before responding to any request. We will ask a few questions in order to confirm your identity. To complete the verification process you must correctly answer one or more questions to confirm identity. If you do not receive a follow up email please contact us at firstname.lastname@example.org or 949-336-7500. Otherwise, we will acknowledge your request and contact you later with our full response.
We will only send CCPA verification questions from email@example.com. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from Us but is not from our CCPA verification email address listed above, do not respond.
Any information we gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request, unless required by law.
Non-Discrimination; Financial Incentives
We estimate the average value of a Client Loyalty Program is $50 per year (which may be higher or lower depending on when you join). We arrived at such value by estimating the approximate retail value of complimentary or discounted products provided through our Client Loyalty Program.
We maintain a Client Interaction Ticketing System (“Ticketing System”) as a means of maintaining, recording & servicing Our Clients Service & Support Needs. Your Personal Information may be present in the Ticketing System and is used for identifying You and Your Business with Us. You may request to have Your Personal Information removed from the Ticketing System. However, such an election will prevent Us from providing Service and Support to You or Your Business. Such an election will cause your Contract with us to be Terminated for Cause and You will be responsible for all outstanding terms, conditions, and dues under such terminated contract.
Deletion of Your Personal Information
You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following the submission of your request if this is the case.
- If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, click here or call 949-336-7500. The link will take you to an interactive form that you can complete and submit to make a request for deletion that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
You may designate an authorized agent to exercise your rights under the CCPA on your behalf.
Pursuant to the CCPA:
- Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
- You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
- We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
- Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This Provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.
Personal Information of Minors
Our websites and mobile applications are not intended for children or minors under the age of sixteen (16) years. Accordingly, we do not knowingly store information from minors under the age of sixteen years. If you believe that a child has submitted Personal Information to Us, please contact us at firstname.lastname@example.org or 949-336-7500.
Right to Opt-Out
You have the right to request that we do not sell Personal Information that we have collected. If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions.
- If you would like to request that we do not sell your Personal Information pursuant to the requirements of the CCPA, click here or call 949-336-7500. The link will take you to an interactive form that you can complete and submit to make a request for deletion; if you use the telephone number, you will be guided through a process that will allow you to submit a request.
- You may also submit a request to opt-out by emailing email@example.com
- If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.
If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell yourPersonal Information.
You have the right to opt-in to the sale of your Personal Information after you have opted out. If you would like to opt-in to the sale of your Personal Information, contact us at firstname.lastname@example.org or 949-336-7500. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.
Additional California Privacy Rights
California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to other parties for their direct marketing purposes. To make such a request, please send an email to email@example.com with the subject “Direct Marketing Information Request.”