Last updated: September 17, 2021
Information We May Collect About You and How We Collect It
We may collect several types of personally identifiable information from and about you including information that falls within the below categories:
|Identifiers||Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers||Yes|
|Categories of personal information described in the California Customer Records Act||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, medical or health insurance information||Yes|
|Characteristics of protected classifications||Race, color, religion, sex (including pregnancy, childbirth and other related medical conditions), gender, gender identity, gender expression, sexual orientation, marital status, medical condition, military or veteran status, national origin, ancestry, physical or mental disability, genetic information, age (over 40)||No|
|Commercial information||Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies||[Yes/No] [Note: Do you keep records of past purchases?]|
|Biometric information||Physiological, biological or behavioral characteristics that can be used to establish individual identity, including imagery of the iris or retina, fingerprint, faceprint, handprint, palmprint, vein patterns, voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health or exercise data that contain identifying information||Yes|
|Internet or other electronic network activity||Browsing history, search history and information regarding a consumer’s interaction with a website, application or advertisement||No|
|Geolocation data||Physical location or movements||No|
|Sensory data||Audio, electronic, visual, thermal, olfactory or similar information||No|
|Professional or employment-related information||Current or past job history or performance evaluations||Yes|
|Education information||Education information including, to the extent not publicly available, the consumer’s name, the name of the consumer’s parent or other family members, the address of the consumer or the consumer’s family, personal identifiers (such as social security numbers, student numbers or biometric records), and indirect identifiers (such as the consumer’s date of birth, place of birth and mother’s maiden name)||No|
|Inferences drawn from personal information||Inferences drawn from any of the aforementioned types of personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes||No|
Collectively, the information described above and any other personally identifying information we may collect from you shall be referred to as “personal information.” We may collect personal information:
- Directly from you if and when you provide it to us, including through the contact page on the Platform, through e-mail and subscription services, if you order a product from us, or if you participate in an activity such as a survey or sweepstakes; and
- Directly from you in connection with your employment by us, including through biometric hand scans.
We ask that you do not send us or disclose any sensitive personal information on or through the Platform or otherwise. Such sensitive information includes racial or ethnic origin, religion or other beliefs, political opinions, health, criminal background or trade union membership.
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings or signals. We do not currently take actions to respond to “Do Not Track” signals. It is our view that a uniform technological standard has not yet been developed. We may adopt a standard once one is created.
Information We Collect from Third Party Sources
We may also collect information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you.
How We Use Your Personal Information
We use information that we collect about you or your devices:
- To present the Platform and its content to you;
- To provide you with information, products or services that you request from us;
- To fulfill any other purpose for which you provide it;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- To notify you about changes to the Platform or any products or services we offer or provide through it;
- To allow you to participate in interactive features on the Platform;
- To conduct research on our users’ demographics, interests and behavior;
- To perform analyses or for other purposes to improve the quality of the Platform and our business;
- To publish our own marketing and promotional materials;
- To invite you to and register you for events;
- To provide you with offers and information about the Platform and our affiliates;
- To deliver targeted advertising, promotions and offers, on behalf of ourselves and advertisers, on and off the Platform;
- To process your requests, purchases, transactions and payments, and prevent transactional fraud;
- If you are employed by us, in connection with your employment including to keep track of your time worked;
- In any other way we may describe when you provide the information; or
- For any other purpose with your consent.
We may also use your information to contact you, via your e-mail address or phone numbers, about our services that may be of interest to you. If you do not want us to use your information in this way, please do not sign up for our subscription services. If you have already received e-mails, phone calls or text messages through our subscription services, and you wish to discontinue the services, you may opt-out by contacting us at email@example.com or (888) 327-8442.
Disclosure of Your Information
We may disclose personal information that we collect or you provide to third parties, including:
- To contractors, service providers and other third parties we use to support the Platform and our business and who are bound by contractual obligations to keep your personal information confidential and use it only for the purposes for which we disclose it to them;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about users is among the assets transferred;
- To our subsidiaries, affiliates and business partners;
- To third parties that provide advertising, content or functionality, or who analyze ad performance, on the Platform or other websites or platforms;
- To fulfill the purpose for which you provide it;
- To publish our own marketing and promotional materials;
- If required by applicable law;
- If we believe disclosure is necessary or appropriate to protect our rights, property or safety and that of our customers or others;
- To comply with a judicial proceeding, court order, law, legal process, other legal obligation or a regulatory or government inquiry;
- If you are employed by us, to our hand scan, timekeeping and/or cloud storage vendors, including Automatic Data Processing, Inc. (ADP) (“Vendors”), in connection with employment matters such as our timekeeping system. For more information on our collection, use, disclosure and retention of employee’s biometric information, please see our Biometric Information Policy;
- For any other purpose disclosed by us when you provide the information; or
- For any other purpose with your consent.
We may disclose your personal information to a third party for business purposes. In the last 12 months, we have disclosed the following categories of personal information:
- Categories of personal information described in the California Customer Records Act
- Biometric information
We have disclosed this information to the following categories of third parties:
- Identifiers: Vendors
- Categories of personal information described in the California Customer Records Act: Vendors
- Biometric information: Vendors
When we disclose personal information for a business purpose, we enter into 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. Any third party with whom we are allowed to share your personal information is authorized to use your personal information in accordance with our contractual obligations with such third parties and in accordance with their own privacy policies, over which we have no control. You agree that we are not responsible or liable for any of their actions or omissions.
You have the right to opt-out of sales of your personal information. We do not sell personal information and we do not knowingly sell the personal information of consumers under the age of 16. In the last 12 months, we have not sold any personal information.
If you provide personal information about another person to us, you will be representing, and we will believe, that you have the consent of that individual to enable us to collect, use or disclose their information as described in this notice, and will rely on our belief and your representation.
Your California Privacy Rights
Shine the Light Protection
California Civil Code Section §1798.83 permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, if applicable. To make such a request, please contact us at firstname.lastname@example.org or (888) 327-8442. If you believe any of the information we possess about you is incorrect, please contact us using the information listed above.
California Consumer Privacy Act of 2018
Consumers protected by the CCPA have specific rights regarding their personal information.
Access to Specific Information
You have the right to request that we disclose to you the following about our collection and use of your personal information over the last 12 months:
- The specific pieces of personal information we collected about you.
- The categories of personal information we have collected about you in the last 12 months.
- The categories of sources from which the personal information was collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom we share the personal information.
- The categories of personal information that we disclosed about you for a business purpose in the last 12 months and, for each category identified, the categories of third parties to whom that particular category of personal information was disclosed for a business purpose.
- The categories of personal information that we sold about you in the last 12 months and, for each category identified, the categories of third parties to whom that particular category of personal information was sold.
We are not required to provide you with these disclosures more than twice within a 12-month period.
If we deny your request for specific pieces of personal information, in whole or in part, because of a conflict with applicable laws or an exception to the CCPA, we will inform you and explain the basis for the denial.
At no point will we ever disclose pursuant to a verifiable consumer request a consumer’s social security number, driver’s license number, other government-issued identification number, financial account number, health insurance or medical identification number, account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. If applicable, we will notify you in response to a request for information that we have collected such information from you.
Right to Request Deletion
You have the right to request that we delete any personal information about you which we have collected from you. Upon receipt of a verifiable consumer request to delete your personal information, we will delete such information and direct our service providers to delete your information from their records, subject to certain exceptions provided in the CCPA including, but not limited to, if it is necessary for us or our service providers to maintain the personal information in order to:
(1) complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us;
(2) detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for that activity;
(3) debug to identify and repair errors that impair existing intended functionality;
(4) exercise free speech, ensure the right of another consumer to exercise his or her free speech, or exercise another right provided for by law;
(5) comply with the California Electronic Communications Privacy Act;
(6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
(7) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
(8) to comply with a legal obligation; or
(9) otherwise use your information, internally, in a lawful manner that is compatible with the context in which you provided the information.
We use a two-step process for requests to delete personal information. First, you must make a verifiable consumer request. After receiving your request, we will contact you to separately confirm that you want your personal information deleted. We will contact you further once your personal information has been deleted.
If we cannot verify the identity of the person requesting deletion of personal information, we may deny the request and will inform the requestor we cannot verify their identity. If we deny your request to delete personal information, we will notify you of the reasons why. We will delete any part of your personal information not covered by the exception allowing us to deny deletion of a portion of your personal information.
If you are covered by the CCPA, we will not discriminate against you merely because you have exercised any of your rights under the CCPA. Except as permitted by the CCPA, we will not, merely because you have exercised your rights under the CCPA, do any of the following:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties;
- Provide you with a different level or quality of goods or services; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
The CCPA provides consumers certain rights with respect to opting out of the sale of personal information. We do not sell your personal information and we do not knowingly sell the personal information of consumers under the age of 16.
To request your right to disclosure or deletion of the personal information we have collected about you, please submit a verifiable consumer request to us by calling us at (888) 327-8442, by emailing us at email@example.com or by writing us at 145 Willow Avenue, City of Industry, California 91746. If you have questions or concerns about our privacy policies or practices, please contact us using any of the previously mentioned methods.
A verifiable consumer request can only be made by you, by you on behalf of your minor child, or by a person or entity registered with the California Secretary of State authorized by you to act on your behalf. In order to ensure we are able to promptly respond to your request, your request should include sufficient information that allows us to verify you are the person about whom we collected personal information or that you are an authorized representative of such person (including, for example, your full name, email address, and mailing address) and a detailed description of what you are requesting. We will review the identifying information provided in your request against information contained in our records to verify the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
If you are using an authorized agent to exercise any of your rights under the CCPA, you must provide us proof in the form of a signed, written authorization of the authorized agent’s ability to act on your behalf. You must also provide us with your full name, email address and mailing address to enable us to verify your identity. We will confirm receipt of your verifiable consumer request within 10 business days of our receipt. We will also provide you with information about our verification process and when you should expect a response.
We will disclose and deliver the personal information required within 45 days of receiving your verifiable consumer request. Should we require more time (up to an additional 45 days), we will notify you of the extension and the reasons for the delay. The disclosure will cover the 12-month period preceding the receipt of your verifiable consumer request.
If requests from you are manifestly unfounded or excessive, we may charge a reasonable fee to respond to your request or we may refuse to act on the request. If we choose not to take action on your request, we will notify you of the reasons behind our decision.
The Platform is not intended for children under 13 years of age. No one under the age of 13 should provide any information to the Platform. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Platform, make any purchases through the Platform, or use any of the interactive features of the Platform. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org or (888) 327-8442. We recommend that parents actively participate in their children’s use of the Internet.
Unfortunately, the transmission of information via the internet is not completely secure. Although we implement reasonable measures to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform, or thereafter. Any transmission of personal information is at your own risk. It is important for you to protect against unauthorized access to your password and to your computer or mobile device. Be sure to sign-off when finished using a shared computer or mobile device and use other reasonable measures to secure your sensitive information. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
Links to Other Websites
We may provide (and permit other parties to provide) links to other websites or resources. Because you acknowledge and agree that we have no control of such websites and resources, we are not responsible for the availability of such websites or resources, and we do not endorse and are not responsible or liable for any content, advertising, products or other materials on or available from such websites or resources. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such website or resource.
Biometric Information Policy
If you are employed by us, we collect certain biometric information from you in connection with your employment and disclose such data to our Vendors. To learn more about our collection, use, disclosure and retention of your biometric information, please visit our Biometric Information Policy.
Contact Information and Refusal to Consent
If you do not consent to the collection, use and disclosure of your personal information, please do not provide us with personal information.