Effective on January 1, 2020, the California Consumer Privacy Act (CCPA) provides consumers (California residents) with specific rights regarding their personal information. If you reside in California, you may exercise the following rights.
- A right to disclosure of the categories of personal information collected by us
- A right to disclosure of the specific pieces of personal information collected by us
- A right to deletion of personal information by us (subject to certain Exceptions outlined below)
- A right to receive personal information in a format that will allow its transfer to third parties by you
- A right to opt-out of the "sale" of personal information, where a "sale" under the CCPA 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 to another business or a third party for monetary or other valuable consideration." We do not sell your personal information.
- A right to sue for security breaches of personal information
Access to specific information and data portability rights
You have the right to request that we disclose to you your personal information we have collected about you over the past 12 months from the day of your request. Once we receive and confirm your request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business and commercial purposes for collecting or selling that personal information.
- The categories of third parties with whom we shared that personal information.
- The specific pieces of personal information we collected about you.
- If we "sold" or disclosed your personal information for a business purpose, up to two separate lists disclosing:
- if we "sold" your personal information, "sales", identifying the personal information categories that each category of recipient "purchased"; and
- if we disclosed your personal information, disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion request rights
You have the right to request that we delete any of personal information data that we collected from you and retained, subject to certain Exceptions (as listed below). Once we receive and confirm your request, we will delete your personal information from our records unless an Exception applies.
We may deny your deletion request if retaining the information is necessary for us or our Provider(s):
- to complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- to debug products to identify and repair errors that impair existing intended functionality;
- to exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- to comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- to engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
- to enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- to comply with a legal obligation; or
- to make other internal and lawful uses of that information that are compatible with the context in which you provided it (each an "Exception" and collectively, "Exceptions").
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- deny you goods or services.
- charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- provide you a different level or quality of goods or services.
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may still offer you certain financial incentives that can result in different prices, rates or service quality levels as permitted by the CCPA. We do not at this provide such financial incentives.
Exercising Access, Data Portability and Deletion Rights
To exercise your rights described above, please submit a request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You may only make a request for access or data portability twice within a 12-month period. The request must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Making a request does not require you to create an account with us. Also, we will only use personal information provided in a request to verify the requestor's identity or authority to make the request.
Your Authorized Agent
You have the right to designate an authorized agent to make a request under the CCPA on your behalf.
Response Timing and Format
We will confirm that we received your request within ten (10) days and will respond within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response electronically or, at your option, by mail.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.