10. NOTICE TO CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “NOTICE TO CALIFORNIA RESIDENTS” section we will refer to this information as “Personal Information.”
If you are a California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available here [ ] for more information on our collection and use of your Personal Information in that capacity.
Notice at Collection of Personal Information
We currently collect and, in the 12 months prior to the Last Updated date of this Policy, have collected the following categories of Personal Information:
- Identifiers (name, postal address, online identifier, Internet Protocol address, email address)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number)
- Telephone number
- Credit card (or other payment account) number
- Insurance policy number
- Medical information
- Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application, or advertisement)
- Geolocation data
- Commercial information (records of personal property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies; or other commercial information)
- Education information
- Professional or employment-related information (including employment history)
- Biometric information (imagery of iris, imagery of retina, fingerprint, imagery of face, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted)
- Characteristics of protected classifications under California or federal law (sex/gender), age (40 and older)
- Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
We collect Personal Information directly from California residents and from advertising networks, data analytics providers, and operating systems and platforms. We do not collect all categories of Personal Information from each source.
In addition to the purposes stated above in the Section “HOW WE USE YOUR INFORMATION” we currently collect and have collected and sold the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your individual consumer’s experience outside the current interaction with us, including, but not limited to, the contextual customization of ads shown as part of the same interaction
- Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
- Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
- Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Sale, Sharing, and Disclosure of Personal Information
The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:
Category of Personal Information | Categories of Third Parties |
Identifiers (name, postal address, online identifier, Internet Protocol address, email address) | Advertising networks; data analytics providers; social media networks |
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device) | Advertising networks; data analytics providers; social media networks |
Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application, or advertisement) | Advertising networks; data analytics providers; social media networks |
Commercial information (records of personal property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies; or other commercial information) | Advertising networks; social media networks |
Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Advertising networks; social media networ |
We sold or shared Personal Information to third parties for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information.
Category of Personal Information | Categories of Recipients |
Identifiers (name, postal address, online identifier, Internet Protocol address, email address) | Subsidiaries and affiliates; operating systems and platforms |
Credit card (or other payment account) information | Payment processors |
Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application, or advertisement) | Subsidiaries and affiliates; operating systems and platforms; social media networks |
Geolocation information | Subsidiaries and affiliates; operating systems and platforms |
Commercial information (records of personal property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies; or other commercial information) | Subsidiaries and affiliates; operating systems and platforms |
Education information | Subsidiaries and affiliates |
Biometric information (imagery of iris, imagery of retina, fingerprint, imagery of face, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted) | Subsidiaries and affiliates; operating systems and platforms |
Characteristics of protected classifications under California or federal law (sex/gender), age (40 and older) | Subsidiaries and affiliates; operating systems and platforms |
Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Subsidiaries and affiliates; operating systems and platforms |
We disclosed Personal Information for the following business or commercial purposes:
- Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
We do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age. We do not use Sensitive Personal Information for purposes other than those the CCPA and its regulations allow for.
Retention of Personal Information
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
Your Rights
If you are a California resident, you have the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
- The right to delete Personal Information that we collected from you, subject to certain exceptions;
- The right to correct inaccurate Personal Information that we maintain about you;
- If we sell or share Personal Information, the right to opt out of the sale or sharing;
- If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, and/or correct through our interactive webform available here or by calling us toll free at 1-866-472-9226.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.
For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
Right to Opt Out of Sale or Sharing of Personal Information
If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.
You may submit a request to opt out of sales or sharing through our interactive webform available by clicking on this link: Do Not Sell or Share My Personal Information. You also may submit a request by calling us a 1-866-472-9226. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. To opt out of our use of third-party advertising Cookies, please see the section “How You Can Opt Out of Cookies” above.