CCPA Policy Supplement

Digital Remedy Privacy Notice for California Residents

Effective Date: January 1, 2020

Last Reviewed on: July 21, 2021

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

 

INFORMATION WE COLLECT 

We may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category

 

Examples

 

Collected

 

A. Identifiers.

 

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.

 

YES

 

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

 

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.

 

YES

 

C. Protected classification characteristics under California or federal law.

 

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).

 

YES

 

D. Commercial information.

 

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

 

YES

 

E. Biometric information.

 

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.

 

NO

 

F. Internet or other similar network activity.

 

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

 

YES

 

G. Geolocation data.

 

Physical location or movements.

 

YES

 

H. Sensory data.

 

Audio, electronic, visual, thermal, olfactory, or similar information.

 

NO

 

I. Professional or employment-related information.

 

Current or past job history or performance evaluations.

 

NO

 

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)).

 

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.

 

NO

 

K. Inferences drawn from other personal information.

 

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

 

NO

 

 

We obtain the categories of personal information listed above from the following categories of sources:

  •   Indirectly from you. For example, from observing your actions on our Website

 

Use of Personal Information

 We may use or disclose the personal information we collect for one or more of the following purposes:

  •       To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  •       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  •       As described to you when collecting your personal information or as otherwise set forth in the CCPA.

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.

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Sharing Personal Information 

We may disclose your personal information to a third party for a business purpose. 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.

 

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category D. Commercial information.

Category F. Internet or other similar network activity.

Category G. Geolocation data.

 

Your Rights and Choices

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

 

Access to Specific Information and Data Portability Rights 

You have the right to request that we disclose certain 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 , 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 (also called a data portability request).
  •       If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  •       sales, identifying the personal information categories that each category of recipient purchased; and
  •       disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

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 , we will delete (and direct our service providers 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 to: 

  •       Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  •       Comply with a legal obligation.
  •       Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through the contact information listed below.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. 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.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer 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.

Personal Information Sales Opt-Out and Opt-In Rights 

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization.Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with 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.

CONTACT INFORMATION 

If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Postal Address:

10 Times Square, 20th Floor, New York, New York 10018 

Attn: Legal Department