California Consumer Privacy Statement
Last updated on: March 20, 2023
This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).
Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the last updated date of this California Consumer Privacy Statement) the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80:signature, physical characteristics or description, state identification card number, bank account number, credit card number, debit card number, other financial information, and medical information
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status and military and veteran status
- Commercial Information: commercial information, including records of products or services purchased, obtained or considered and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, such as browsing history, search history and information regarding your interaction with websites, applications or advertisements
- Sensory Information: audio, electronic, visual, and similar information
- Employment Information: professional or employment-related information, such as resume information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information and pre-employment screening and background check information, including criminal records information
- Education Information
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage or providing similar services;
- Providing advertising and marketing services;
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance;
- Short-term, transient use, such as nonpersonalized advertising shown as part of your current interaction with us;
- Helping to ensure security and integrity;
- Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade or enhance them;
- Debugging to identify and repair errors;
- Undertaking internal research for technological development and demonstration;
- Managing career opportunities with us; and
- Managing our relationships with current or prospective partners, vendors and other business partners.
We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.
To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
Retention of Personal Information
Sources of Personal Information
During the 12-month period prior to the last updated date of this California Consumer Privacy Statement, we may have obtained personal information about you from the following categories of sources:
- Directly from you, such as when you contact us
- Your devices, such as when you use our websites or apps
- Our affiliates and subsidiaries
- Service providers, contractors and other vendors who provide services on our behalf
- Others who use our websites, apps or Services, such as your family, friends or employer
- Online advertising and data analytics services
- Internet service providers (“ISPs”) and operating systems and platforms
- Social networks
- Recruiting and talent agencies
- Job references, such as your employers or teachers
- Data brokers, such as public databases
- Credit bureaus and providers of credit reporting or background check services
Sale or Sharing of Personal Information
We do not sell your personal information in exchange for monetary compensation. We may share your personal information by allowing certain third parties (such as online advertising services) to collect personal information via automated technologies on our websites and apps for cross-context behavioral advertising purposes. This kind of sharing may be considered a “sale” under California law when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information.
We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the last updated date of this California Consumer Privacy Statement) the following categories of personal information about you to online advertising services:
- Commercial Information
- Online Activity
You have the right to opt-out of this disclosure of your information, as detailed below. We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.
Disclosure of Personal Information
During the 12-month period prior to the last updated date of this California Consumer Privacy Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
|Category of Personal Information
|Categories of Third Parties
|Additional Data Subject to Cal. Civ. Code § 1798.80
In addition to the categories of third parties identified above, during the 12-month period prior to the last updated date of this California Consumer Privacy Statement, we may have disclosed personal information about you to government entities, and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.
California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
- Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold or shared about you.
- Correction: You have the right to request that we correct the personal information we maintain about you if that information is inaccurate.
- Deletion: You have the right to request that we delete certain personal information we have collected from you.
- Opt–Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
- Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
How to Submit a Request. To submit an access, correction, deletion or Shine the Light request, please contact us by calling us at 1-888-642-4361. You can also contact us by emailing [email protected]. You can opt-out of the sale or sharing of your personal information by clicking here or broadcasting the Global Privacy Control signal. To submit a request as an authorized agent on behalf of a consumer, please contact [email protected]. For questions or concerns about our privacy policies and practices, please call us at 1-888-642-4361 or send us an email to [email protected].
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion or correction request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to, correction of or deletion of your personal information, we may verify your identity by requiring you to authenticate your email address or providing information about your transactions or prior interactions with us. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you submit a request through an authorized agent, we may ask for your written permission or a power of attorney. In the event you provided your authorized agent with a written permission, we will require that you also verify your identity.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.