Last Updated: April 6, 2021
Adrenaline LLC (“Adrenaline”, “we,” “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Notice. Please read this Privacy Notice carefully to understand our policies and practices regarding your personal information and how we collect, store, process, transfer, share and use your personal information. “Personal information” means any information that identifies or can be associated with you.
By accessing, downloading, registering with, or otherwise using our websites, services and applications (collectively, the “Services”), you (“you”, “your” or “User”) or the organization with which you are affiliated (“Organization”) agree to this Privacy Notice. This Privacy Notice applies to all personal information we collect through our Services, even if you have not registered with the Services or otherwise established an account with us. If you do not agree with our policies and practices, please do not access, download, register with, or use the Services. Capitalized terms that are not defined in this Privacy Notice have the meaning given to them in the Adrenaline Terms of Service, which govern your use of the Services. This Privacy Notice is incorporated into and forms a part of the Adrenaline Terms of Service.
Please note that this Privacy Notice does not apply to the use of personal information collected outside of the Services, including personal information:
· We collect offline;
· Collected on any third party apps, services or websites, including websites you may access through the Services; or
· You provide to, or that is collected by, any third party data controller.
Those third parties may have their own privacy policies, which we encourage you to read before providing information to or through them. We do not accept any responsibility or liability for their privacy policies or any information you provide to or through them.
Please note that if you choose not to provide us with your information, we may not be able to provide some or all of the Services or respond to your other requests.
2. DATA CONTROLLER
A “data controller” is a person or organization who alone (or jointly) determines the purposes for which, and the way that, any personal information is, or is likely to be, processed. Adrenaline is the data controller of your personal information collected through or otherwise provided to the Services.
3. INFORMATION WE COLLECT AND HOW WE COLLECT IT
3.1. Categories of Information
When you use the Services, the categories of personal information about you that we collect may include:
· your contact information (such as your name, work email address and telephone number)
o first name
o last name
o email address
o postal address
o business phone number
· your business information (such as the name and location of your Organization)
· your employment information (such as your title or role)
· your account name
· your payment information
· your mobile device and (when enabled) your location information
· other information provided by third parties (including your Organization)
· any information you may choose to provide when you fill out a “free text” box on forms available through the Services (for example, your comments and opinions that you express when you comment on a blog post or other content posted through the Services, or when you contact us by email, mail or phone).
We may collect your personal information when you provide it to us directly or when your Organization provides it to us on your behalf.
The table in Attachment 1 further sets forth the categories of information we collect about you when you use the Services and how (for which purpose) we use that information. The table also lists the legal basis which we rely on to process the information.
3.2. Information You Provide to Us
When you access, download, register with, or use the Services, or when you otherwise contact us, we may ask you to provide, or you may voluntarily provide, information, including personal information, to provide you with Services or the support you request.
· Account information: An account is required for certain features of the Services. If you register for an account, we may require certain information, such as your first and last name, Organization name, email address, and password.
· Payment information: When you use our Services to make, accept, request, or record payments, we may require you to provide certain billing details, contact information (e.g., your name, business name, address, email address, and phone number), financial information corresponding to the selected Services (e.g., a credit card number and expiration date or a bank account number), and in some instances identification information (e.g., date of birth, social security number, or tax identification number).
· Other information you provide: You may choose to voluntarily provide additional information to us (for example, by filling out and submitting online and other forms for events, webinars, or whitepapers; responding to surveys; participating in contests, promotions or other marketing activities; providing suggestions or improvements; posting content via our sites or applications; or which you otherwise choose to submit through the Services).
3.3. Information Automatically Collected and Tracked
When you access, download, register with, or use the Services, they may use technology to automatically collect information, including personal information, about the Services and how you use them.
· Usage details: When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services.
· Device information: We may collect information about your device (mobile, computer or otherwise) and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
· Stored information and files: The Services also may access metadata and other information associated with other files stored on your device.
· Location information: The Services may collect information about the location of your device and other location-based information.
· Behavioral information: We also may use technologies to collect information about your activities over time and across third-party websites, apps, or other online services (i.e., behavioral or interest-based tracking).
· Transaction information: When you use our Services to make, accept, request, or record payments, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing information, the devices and payment methods used to complete the transactions, and other related transaction details.
The technologies we use for automatic information collection may include:
· Web Beacons. Certain pages or sites in the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
· Flash Local Shared Objects (LSOs). When we post videos or other media on the Services, third parties may use local shared objects (LSOs), also known as Flash cookies, to store your choices for things like volume control or to further personalize certain features. Cookie management tools provided by your browser will not delete Flash cookies. To learn how to manage privacy and storage setting for Flash cookies, visit www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html#117118.
We use the information collected automatically to present the Services to you on your device; to determine news, alerts and other products and services that may be of interest to you for marketing purposes; to monitor, support and improve the Services and our business; and to help us develop new products and services. The table in Attachment 2 further sets forth the categories of information we collect about you automatically when you use the Services and how (for which purpose) we use that information. The table also lists the legal basis which we rely on to process the information.
3.4. Information We Collect from Third Parties
We may collect information, including personal information, that others provide about you when they use the Services, or obtain information from other sources (including social media networks) and combine that with information we collect through the Services. Any information request regarding the disclosure of your personal information to us should be directed to such third parties.
· Third Party Services. When you use the Services or any content made available through the Services, certain third parties may use automatic information collection and tracking technologies to collect information about you or your device. These third parties may include advertisers, ad networks, and ad servers; analytics companies; your mobile device manufacturer; your mobile service provider; and other third parties. We do not control third parties’ collection or use of your information to serve interest-based advertising. This information varies and is controlled by those third party services or as authorized by you via your privacy settings with those services.
· Clients/Marketing Service Providers/Business Partners. We may also receive information collected by our clients and marketing service providers on our behalf, including marketing lead generation service providers, marketing opt-in lists or other data aggregators, as well as information shared with us through referrals by our business partners. This information may include the address and purchasing histories/preferences of our clients’ customers, as well as the goods and services those customers have purchased.
· Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data, identity or account verification information, or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you.
4. HOW WE USE YOUR INFORMATION
We generally rely on the following three main bases to process your personal information:
· to perform the contract we are about to enter into or have entered into with you, including the Adrenaline Terms of Service, this Privacy Notice, and other agreements and policies;
· for our legitimate interests or those of a third party, where your rights and interests do not override those interests; or
· to comply with a legal or regulatory obligation.
Sometimes, we may rely on other legal bases to process your information, such as where you have given us consent to use your personal information in certain ways or to protect a user’s vital interest. We also may process your personal information relying on more than one legal basis, depending on the specific purpose for which we are using your personal information.
As noted above, the table in Attachment 1 provides further details on the categories of information we collect about you when you use the Services, how (for which purpose) we use that information, and the legal basis we rely on to process that information. You can also contact us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set forth below.
4.2. Provide Our Services
We use your information to provide or facilitate:
· Access to, and use and support of, the Services
· Payment processing and account management
· Customer service and support
· Updates, security alerts, and account notifications
· Other services requested by you as described when we collect the information
We process your personal information where it is necessary for the adequate performance of the contract with you. We also process this information given our legitimate interest in providing the Services in an effective manner.
4.3. Understand and Improve Our Services
We use your information to analyze, operate, protect, improve, and customize the Services and user experience, such as by performing data analytics and studying how the Services are used. We process this information given our legitimate interest in improving the Services, understanding how our Services are being used, and developing and growing our business.
4.4. Administer and Protect the Services
We use your information to:
· Prevent, detect, investigate, and mitigate fraud, security incidents, abuse, or other potentially harmful or illegal activities
· Maintain the network and information security to protect information against loss, damage, theft or unauthorized access
· Perform troubleshooting, testing, and system maintenance
· Conduct security investigations and risk assessments
· Verify your identity
· Conduct checks against databases and other information sources, to the extent permitted by applicable laws and with your consent where required
We process your personal information where it is necessary to comply with applicable laws and regulations. We also process this information given our legitimate interest in providing administrative and information technology services, ensuring network and information security, and complying with applicable laws and regulations.
4.5. Legal and Safety
We use your information to:
· Prevent, detect, investigate, and mitigate fraud, security incidents, abuse, or other potentially harmful or illegal activities
· Comply with our legal obligations, including managing legal and regulatory requests and requirements
· Enforce or defend our rights under our Terms of Service, Privacy Notice, and other agreements and policies
· Resolve any disputes with any of our users and enforce our agreements with third parties
We process your personal information where it is necessary to comply with applicable laws and regulations or to ensure adequate performance of the contract with you. We also process this information given our legitimate interest in protecting our Services, preventing harm or illegal activities, enforcing or defending our legal rights, and complying with applicable laws and regulations.
4.6. Provide and Improve Our Marketing
· Send you promotional messages, marketing, advertising, and other information that we think may be of interest to you
· Personalize, measure, and improve our marketing and advertising
· Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Adrenaline or its third-party partners
· Analyze, operate, protect, improve, and customize the Services and user experience, such as by performing data analytics and studying how the Services are used
We will process your personal information given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest, informing our marketing strategies, and developing and growing our business. Generally, and unless you are a resident of the European Economic Area (EEA), we do not rely on your consent as a basis for processing your personal information other than in relation to sending third-party direct marketing communications to you via email or text message. Where we collect your personal information with consent, you may withdraw your consent for us to use your information at any time by unsubscribing, managing your preferences through your account, or contacting us (See “Your Choices About our Marketing Activities” below).
5. DISCLOSURE OF YOUR PERSONAL INFORMATION
We share personal information collected through the Services as follows:
· With your consent
· With other users (including your affiliates or similar related business entities) in connection with the Services
· If you use an account or profile associated with another party, we may share your information with the owners of that profile (for example, if you are an employee using your Organization’s account or profile to communicate with us)
· With contractors, service providers, and business partners. This may include payment processors, marketing and CRM providers, cloud storage providers, attorneys, accountants, data analytics providers, and strategic partners.
· With our corporate family of companies that are related by common ownership or control, to enable us to provide (or support us in providing) the Services
· With 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 Adrenaline’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Adrenaline about the Services and users are among the assets transferred
· With third parties to market their products or services to you if you have consented to/not opted out of these disclosures
· For any purpose disclosed by us when you provide the information
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request
· To enforce our rights arising from any contracts entered into between you and us, including the Terms of Service, and for billing and collection
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of, our customers or others
· We may also share aggregated information (information about our users that we combine so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
6. YOUR CHOICES ABOUT OUR MARKETING ACTIVITIES
6.1. Marketing Communications for Non-EEA Residents
From time to time, you may receive marketing communications from us if you have requested information from us or purchased services from us and, in each case (unless you are a resident of the European Economic Area (EEA)), you have not opted out of receiving such communications. If you are a resident of the EEA, you will not receive such communications from us unless you have specifically opted in to receive them, as described further in Section 6.4 (EEA Residents) below. In any case, most such communications we send will be by email. For some communications, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
You can ask us to stop sending you marketing messages at any time by contacting us at email@example.com or by using the contact information set forth below.
6.3. Third Party Marketing
We will get your express opt-in consent before we share your personal information with any company outside Adrenaline’s corporate family for marketing purposes.
6.4. EEA Residents
If you are resident in the EEA, we will only send you marketing messages if you have given us your consent to do so. If you do not want to receive messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details or by refusing or withdrawing your consent. You can also change your preferences later by clicking on the unsubscribe link at the bottom of our messages or by emailing us at firstname.lastname@example.org.
6.5. Non-Marketing Messages
Please note that even if you do opt out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages.
6.6. Affiliate Usage
Your personal information may also be shared with any affiliates of Adrenaline, who may also use this information for the same purposes outlined in this Privacy Notice.
7. INTEREST-BASED ADVERTISING
7.1. Interest-Based Advertising
We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. If so, we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of the Services over time so that they may play or display ads on the Services, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
7.2. Online Resources
To learn about interest-based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices or the DAA’s resources at www.aboutads.info/choices. Please note that opting out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use. In addition, some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt out again.
8. PRIVACY SETTINGS
Any content you post on the Services may be viewed by other users in accordance with privacy settings available through the Services. We can, but have no obligation to, monitor your content, and we can remove any content or other information you post for any reason or no reason.
9. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
If you are resident in the European Economic Area (EEA), under the General Data Protection Regulation (GDPR) you have the following rights in respect of your personal information that we hold:
· Right of access. You have the right to obtain:
o confirmation of whether, and where, we are processing your personal information;
o information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
o information about the categories of recipients with whom we may share your personal information; and
o a copy of the personal information we hold about you.
· Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
· Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
· Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
· Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
· Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
If you are resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death.
If you are concerned about the personal information collected as you use our Services or would like to discuss or exercise rights you may have under this Privacy Notice or applicable law, you may contact us at email@example.com. If we are acting as a data controller with respect to the personal information at issue (e.g., personal information collected via the Services), we will respond to your request directly. If we are acting as a processor of your personal information on behalf of a third party data controller, then we will forward your request to that data controller to allow them to respond. If the third party data controller then requests Adrenaline to facilitate your request with respect to any personal information with respect to which we are the processor, we will respond to the third party data controller’s request as quickly as is practicable under the circumstances. You may also contact the third party data controller directly if you have questions about the personal information with respect to which it is the data controller.
10. DATA RETENTION
We will retain your personal information for no longer than necessary for the purposes for which it was collected (as described in further detail in Attachments 1 and 2), as requested by our clients, and if necessary, to comply with our legal obligations and legitimate business interests. If you no longer want us to use your personal information to provide the Services to you, you can request that we erase your personal information and close your account. Please be aware that because we maintain the Services to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
11. DATA SECURITY
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. If you have any questions about the security of our Services, please contact us at firstname.lastname@example.org.
12. CHILDREN UNDER THE AGE OF 16
The Services are not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com or by using the contact information set forth below.
13. YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at firstname.lastname@example.org.
In addition, under the California Consumer Privacy Act (CCPA), California residents have certain rights, and we have certain responsibilities. If you are a California resident, please consult our California Privacy Notice.
14. INTERNATIONAL DATA TRANSFER
Your personal information may be transferred to, stored, and processed in the United States or a country that is not regarded as providing the same level of protection for personal information as the laws of your home country. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information.
Whenever we transfer the personal information of individuals resident in the European Economic Area (EEA) to countries out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
· Where we use certain service providers, we may use specific contractual provisions approved by the European Commission which give personal information the same protection it has in the EEA.
15. CHANGES TO OUR PRIVACY NOTICE
We may update our Privacy Notice from time to time. If we make material changes to how we treat our users’ personal information, we will post the new Privacy Notice on this page with a notice that the Privacy Notice has been updated and notify you by email to the primary email address and/or phone number specified in your account, or an in-Services alert the first time you use the Services after we make the change. Modifications will be effective as of the date stated on the update, or such other date as communicated in the notice to you.
The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this Privacy Notice to check for any changes.
16. LODGING COMPLAINTS
You have the right to lodge complaints about the data processing activities carried out by Adrenaline before your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. In addition, residents in other jurisdictions may also have similar rights to the above. Please contact us at email@example.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.
17. CONTACT INFORMATION
To ask questions or comment about this Privacy Notice or our privacy practices, contact us at firstname.lastname@example.org or Adrenaline LLC, [ADDRESS].
PERSONAL INFORMATION WE COLLECT WHEN YOU USE THE SERVICES
|Category of personal information||How we use it (purpose of use)||Legal basis for the processing|
|Contact informationPersonal information, such as your name, phone number, address, and e-mail address||We use this information to address your inquiries or complaints you make (or are made about you) regarding the Services.We use your email to uniquely identify you as a user in the system and also to authenticate and authorize you during login.We may also use this information to market our goods and services to you, to provide you with information that you request, or to register you for an event.||This processing is necessary for our legitimate interests, namely administering the Services, addressing inquiries and complaints regarding the Services, and for purposes of performing our contract with you or your Organization.|
|Business informationYour business information, such as the name, size and location of your Organization||We use this information to market our goods and services to you.||This processing is necessary for our legitimate interests, namely administering the Services, addressing inquiries and complaints regarding the Services, and for purposes of performing our contract with you or your Organization.|
|Employment informationYour employment information||We use this information to market our goods and services to you.||This processing is necessary for our legitimate interests, namely administering the Services, addressing inquiries and complaints regarding the Services, and for purposes of performing our contract with you or your Organization.|
|Other information provided by third partiesOther information provided by third parties||We use this information to market our goods and services to you, to provide services to our clients and to analyze and improve the Services.||This processing is necessary for our legitimate interests, namely administering the Services, addressing inquiries and complaints regarding the Services, and for purposes of performing our contract with you or your Organization.|
|Other information you choose to provideAny information you may choose to provide when you use the chat functionality available through the Services or fill out a “free text” box on forms available through the Services (for example, your comments and opinions that you express when you comment on a blog post or other content posted through the Services, or when you interact with us by chat, email, mail or phone).||We cannot limit what personal information you may choose to provide, for example, in free text boxes or other interactive features made available through the Services.We may use this information to market our goods and services to you, to provide you with information that you request, to register you for an event, or to address any concerns or complaints you may have about the Services.||This processing is necessary for our legitimate interests, namely administering the Services, addressing inquiries and complaints regarding the Services, and for purposes of performing our contract with you or your Organization.|
PERSONAL INFORMATION COLLECTED AUTOMATICALLY
|Category of personal information||How we use it (purpose of use)||Legal basis for the processing|
|Information about how you access and use the Services.For example, the Services collect the IP address of your Device, your location, and the type of browser you are using to access the Services.||We use this information to improve the Services and to support users in connection with any technical issues, such as the performance of the Services.||The processing is necessary for our legitimate interests, namely, to improve the Services generally; to monitor and resolve issues; and for the detection and prevention of fraud.|
|We use this information (like your IP address) to enhance the security of the Services (for example, so that we can potentially block malicious IP addresses).||The processing is necessary for our legitimate interests, namely, to improve the Services generally; to monitor and resolve issues; and for the detection and prevention of fraud.|
YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT
This California Privacy Notice supplements the Adrenaline Privacy Notice (the “Notice”) and contains the disclosures required under the California Consumer Privacy Act (CCPA). For individuals who are California residents, the CCPA requires covered businesses to make certain disclosures about the categories of personal information they collect and how they use it, the categories of sources from which they collect personal information, and the third parties with which they share it. You also have the right to exercise certain rights regarding your personal information.
Please note that for California residents, the term “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 as defined in the CCPA. Unless otherwise defined in this document, all capitalized terms have the same meaning as given them in the Notice.
If you are a California resident who has provided personal information to Adrenaline, or a California resident who reasonably believes that Adrenaline collected or stores your personal information, you have the right to request Adrenaline to:
· Disclose the categories of personal information we collected about you in the preceding twelve months; categories of sources from which the personal information was collected; the business or commercial purpose for which we collected or sold the personal information; the categories of third parties with which we have shared your personal information; categories of personal information that we sold in the preceding twelve months, and for each category identified, categories of third parties to which we sold that particular category of personal information; and the categories of personal information that we disclosed for a business purpose in the preceding twelve months, and for each category identified, the categories of third parties to which we disclosed that particular category of personal information (“Request to Know”)
· Disclose the specific pieces of personal information that we have collected on you (“Request to Know”)
· Delete personal information we have collected on you (“Request to Delete”)
You can only make to Requests to Know in a twelve-month period, and the information provided need only cover the twelve-month period prior to the receipt of your request.
WE DO NOT “SELL” YOUR PERSONAL INFORMATION AS “SELL” IS DEFINED IN THE CCPA.
Methods for Submitting Request
You may submit Requests to Know and Requests to Delete in one of the following methods: (1) by submitting an online form; (2) sending an e-mail to email@example.com; or (3) by calling the following number: [ ].
Verification of Requests
We will need to verify your identity to respond to Requests to Delete and Requests to Know. If you have an account with us that is password-protected, we can request from you two data points of personal information to verify your identity. If you do not have an account with us, and your request concerns specific pieces of personal information, we can request from you at least three data points of personal information as well as a signed declaration under penalty of perjury to verify your identity.
If a request concerns household information, and the household does not have a password-protected account with us, we will not comply with a Request to Know specific pieces of personal information about the household or a Request to Delete household personal information unless all of the following conditions are satisfied:
· all consumers of the household jointly request access to specific pieces of information for the household or the deletion of household personal information;
· we have individually verified all members of the household in accordance with the CCPA; and
· we have verified that each member making the request is currently a member of the household.
Time for Response
Please note that one you have submitted a Request to Know or Request to Delete, we will acknowledge your request within ten business days. If, for some reason, you do not receive such a receipt within ten business days of your submitted request, please send an email to firstname.lastname@example.org, as an error may have occurred.
We will respond to Requests to Know and Requests to Delete within forty-five calendar days after they are received. If we cannot verify you within the forty-five day period, we may deny the request. If necessary, we may take up to an additional forty-five calendar days to respond to your request, for a maximum of ninety calendar days from the day the request is received, provided that we provide you with notice and an explanation of the reason that we will take more than forty-five calendar days to respond to your request.
As a California resident, you have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us at email@example.com for more information if you wish to submit a request through an authorized agent.
Right to Non-Discrimination for the Exercise of CCPA Rights
You have a right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA. We hereby inform you that if you exercise any of your rights under the CCPA, we may not deny you goods or services for that reason, or subject you to different prices than those paid by other consumers, except to those permitted under the CCPA.
If you have any questions about our privacy policies or practices or this document, please contact us at firstname.lastname@example.org.
Notice at Collection
Pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of personal information that we collect through the Services, the business or commercial purposes for which such personal information was collected, the categories of sources of such personal information, and the categories of third parties to which such information was disclosed in the past 12 months.
|Category||Collected||Business or Commercial Purpose||Categories of Sources||Categories of Third Parties to Which Disclosed|
|Identifiers||YESWe collect such items as your real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, or other similar identifiers.||We collect and store these personal identifiers in order to:· provide you a better experience· provide services to our clients· communicate with clients for marketing and sales purposes||UsersClients||We may provide this information back to the same client that provided it to us.Otherwise, we do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Personal Information Categories Listed in the California Consumer Records Statute (California Civil Code Section 1798.80(e))||YESWe may collect a User’s name, signature, address, business telephone number, employment information, bank account number, credit card number, debit card number, or any other financial information.||We collect and store these categories of personal information in order to:· provide you a better experience· provide services to our clients· communicate with Users for marketing and sales purposes||Users||We do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Protected Classification Characteristics Under California or Federal Law||NO|
|Commercial Information||YESWe store records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.||We collect and store commercial information to provide services to our clients and to improve our Services.||Clients provide us information about their customers so that we can provide services to our clients.Users interact with the Services. These interactions sometimes create a history, such as an indication of interest in one of our goods or services, a request for more information, or a request to download material.||We may provide this information back to the same client that provided it to us.We do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Biometric Information||NOWe do not collect 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.|
|Internet or Other Similar Network Activity||YESWe may store and use browsing history, search history, information on your interaction with a website, application or advertisement.||We monitor and may store information about the way you interact with the Services in order to provide you a better experience, find flaws in our interface and improve our business process.||UsersThird parties (e.g., Bombora and Leadfeeder)||We do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Geolocation Data||NOWe do not collect your physical location.|
|Sensory Data||NOWe do not collect audio, electronic, visual, thermal, olfactory, or similar information.|
|Professional or Employment-Related Information||YESWe collect current or past job information.||We collect this information in order to market our goods and services to existing and prospective clients.||Clients||We store and maintain this information in our customer relationship management (CRM) platform. Otherwise, we do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Non-Public Education Information (Pursuant to the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||NOWe do not collect education records directly related to a student maintained by an educational institution that receives federal funds or a party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.|
|Inferences Drawn from Other Personal Information||YESWe create profiles reflecting our clients’ customers’ preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||We collect this information in order to provide services to our clients.||Clients provide us information about their customers so that we can provide services to our clients.||We may provide this information back to the same client that provided it to us.We do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|