This California Consumer Act Privacy Notice (“CCPA Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”). For the purpose of this CCPA Notice, personal information applies to “Personal Information” as defined by the CCPA (also referred to herein as “PI”).
We collect and share the following categories of PI from the corresponding sources and for the corresponding purposes set forth in the table below.
In addition, we may collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.
We do not knowingly “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third-party cookies and tracking devices associated with our websites and mobile apps may constitute a “sale” of your PI as defined by the CCPA. You can exercise control over browser-based cookies by adjusting the settings on your browser. We also list cookies and provide access to their privacy information and, if available, opt-out programs in our Cookie Policy. Further, you can learn more about your choices regarding certain kinds of online interest-based advertising with the Digital Advertising Alliance or the Network Advertising Initiative. We do not represent that these third-party tools, programs, or statements are complete or accurate.
Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you, so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.
California Consumers have the right to exercise privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. In order to verify your identity, we will send you an email to the email address that you provide to us, and you must take action as described in our email. This will enable us to verify that the person who made the request controls and has access to the email address associated with the request. We will check our systems for the email address that you provide, and any information associated with such email address. If you provide us with an email address that has not been used to interact with us, then we will not be able to verify your identity. In other words, the only reasonable method by which we may verify the identity of individuals is if we have an email address on file that was provided to us in relation to our services. We will be unable to fulfill your request if we cannot verify your identity.
Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
In order to verify your identity, we will send you an email to the email address that you provide to us, and you must take action as described in our email. This will enable us to verify that the person who made the request controls and has access to the email address associated with the request. We will check our systems for the email address that you provide, and any information associated with such email address. If you provide us with an email address that has not been used to interact with us, then we will not be able to verify your identity. In other words, the only reasonable method by which we may verify the identity of individuals is if we have an email address on file that was provided to us in relation to our services. We will be unable to fulfill your request if we cannot verify your identity.