Effective Date: January 1, 2020
Last Amended: February 11, 2020
Definitions Specific to this Policy
“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. Personal Information does not include publicly available information obtained from government records; deidentified or aggregated consumer information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.
“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
“Third Party” means a person or entity who is not a business that collects Personal Information from consumers, as defined in the CCPA, and to whom the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
The Personal Information We Collect and Disclose
The chart below shows the categories of Personal Information we may collect; examples of the type of Personal Information in each category; all types of sources from which each category of Personal Information is collected; the business purpose(s) for which that category of Personal Information is collected; and all types of third parties with whom that category of Personal Information is shared. As this chart shows, we sell certain Personal Information to third parties.
|Category of Personal Information||Examples||Types of Sources from which this Category of Personal Information Is Collected||Business Purposes for Collection||Types of Third Parties with Whom this Category of Personal Information is Shared/Sold and/or Disclosed|
|Unique identifiers||Name, signature, address, telephone email, account name, online identifier, IP address||
|Financial information||Credit card number, debit card number, or any other financial information||
|Purchase history||Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||
|Internet activity||Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement||
|Geolocation data||Geolocation data||
We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.
Personal Information of Minors
We are proud of our online information and we strive to ensure we do not offend people of any age. However, our web pages are not intended for children or minors under the age of sixteen years. Accordingly, we do not store information from minors under the age of sixteen years. If you believe that a child has submitted personal information to us, please contact us at firstname.lastname@example.org and we will delete the information.
You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
- If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of Personal Information sold; (3) the categories of third parties to whom the information was sold; and (4) the categories of Personal Information that were disclosed for a business purpose, you may submit a request via this form or call us at 1-888-996-2813. The form will provide you with instructions for submitting your CCPA request.
- If you would like to request the specific pieces of Personal Information we collected about you, you may submit a request via this form or call us at 1-888-996-2813. The link will provide you with instructions for submitting your CCPA request.
Deletion of Your Personal Information
You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
- If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, you may submit a request via this form or call us at 1-888-996-2813. The form will provide you with instructions for submitting your CCPA request.
Right to Opt-Out
You have the right to request that we do not sell Personal Information that we have collected. If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions.
- If you would like to request that we do not sell your Personal Information pursuant to the requirements of the CCPA, you may submit a request via this form or call us at 1-888-996-2813. The form will provide you with instructions for submitting your CCPA request.
- If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.
If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell your Personal Information.
You have the right to opt-in to the sale of your Personal Information after you have opted out. If you would like to opt-in to the sale of your Personal Information, please email us at email@example.com or call us at 1-888-996-2813.
In order to protect your information, we will confirm a requestor’s identity before responding to any request. If we are unable to identify you based on the information you provide with your request as compared with our records based on your previous interaction with us, we will let you know and may ask additional questions.
We will only send CCPA verification questions from firstname.lastname@example.org. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our CCPA verification email address listed above, do not respond.
Any information we gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request.
You may designate an authorized agent to exercise your rights under the CCPA on your behalf.
Pursuant to the CCPA:
- Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
- You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
- We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
- Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.
Additional California Privacy Rights
California Civil Code Section § 1798.83 permits users of our web site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to email@example.com with the subject “Shine the Light Request.”