Last updated: July 20, 2022
1. Our Personal Information Handling Practices over the preceding 12 months
Below are categories of personal information we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties to whom we disclose the personal information.
|Category of Personal Information||Purpose of Processing||Sources of Personal Information||To Whom Disclosed|
|Identifiers such as name, postal address, Internet Protocol address, email address||Responding to inquiries and considering requestsEvaluating job applicationsFilling ordersMaintaining, securing, customizing and improving our Web siteSending promotional communications Maintaining our IT systems with infrastructure backups and testingOperating, evaluating and improving our businessExercising our legal rights, defending and advance our legal interests, complying with applicable laws such as data protection laws, and protecting against fraudulent, harmful and illegal activity||Directly from California residents, for example, when filling out forms or applications||Service providers who assist us in providing our site, products and services or operating our business|
|Personal information categories described in the California Records statute § 1798.80(e) such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account, credit card, and debit card numbers, or any other financial, medical, or health insurance information, including sleep, health, or exercise data Some categories may overlap with other categories||Same as above||Same as above||Same as above|
|Protected classifications under California or federal law such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)||Evaluating job applications||Same as above||Same as above|
|Commercial information such as products or services purchased, obtained, or considered||Responding to inquiries and considering requestsFilling ordersSending promotional communications Operating, evaluating and improving our businessExercising our legal rights, defending and advance our legal interests, complying with applicable laws such as data protection laws, and protecting against fraudulent, harmful and illegal activity||Same as above||Same as above|
|Biometric information, such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns||Not collected||N/A||N/A|
|Internet or other similar network activity such as browsing history, search history, and information regarding a California resident’s interaction with a website, application, or advertisement||Maintaining, securing, customizing and improving our Web siteMaintaining our IT systems with infrastructure backups and testingOperating, evaluating and improving our businessExercising our legal rights, defending and advance our legal interests, complying with applicable laws such as data protection laws, and protecting against fraudulent, harmful and illegal activity||Directly from California residents||Service providers who assist us in providing our site, products and services or operating our business|
|Geolocation data such as physical location or movements||Same as above||Same as above||Same as above|
|Sensory data such as audio, electronic, visual, thermal, olfactory, or similar information||Same as above||Same as above||Same as above|
|Professional or employment-related information such as current or past job history or performance evaluations||Evaluating job applications||Directly from California residents Indirectly from public sources or from third parties, such as background check providers||Same as above|
|Non-public education information (under the Family Educational Rights and Privacy Act at 20 U.S.C. § 1232g, 34 C.F.R. Part 99)||Evaluating job applications||Same as above||Same as above|
|Inferences drawn from other personal information such as the consumer’s preferences, characteristics, and behavior||Sending promotional communications Operating, evaluating and improving our business||Directly from California residents||Same as above|
2. No Sales of Personal Information
We do not sell California residents’ personal information. We do not have actual knowledge that we sell the personal information of California residents under 16 years of age.
3. Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that we disclose what personal information we collect, use, disclose and share about you. To submit a request to exercise this right, please see the “Exercising Your Rights” section further below.
4. Right to Request Deletion of Personal Information
You have the right to request the deletion of personal information about you that we collected from you. To submit a request to delete personal information, please see the “Exercising Your Rights” section further below.
5. Exercising Your Rights
To exercise your rights under the CCPA, please email us at email@example.com.
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. You may designate an authorized agent by taking the steps outlined under “Authorized Agent” further below.
You may only make a request for access or data portability twice within a 12-month period.
In your request or in response to us seeking additional information, you, or your authorized agent, must:
- Provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected which will depend on your prior interactions with us and the sensitivity of the personal information being requested; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfil your request. We will only use the personal information you provide to us in a request for the purposes of verifying your identity and to fulfill your request.
Any disclosures we provide will only cover the 12-month period preceding receipt of your request.
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.
6. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you for electing to exercise any rights under the CCPA.
7. Authorized Agent
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- The authorized agent verifies his or her own identity directly with us by contacting us by phone or email as provided under Section 5 above; or
- You directly confirm with us that you provided the authorized agent permission to submit the request. To do so, you must contact us using the methods provided under Section 5 above; or
- You sign a written statement that you authorize the agent to act on your behalf.
- Please note that we may need to verify your identity, and may request you to provide additional information in order to verify your identity. The information that we ask from you will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465, it may not be necessary to perform the above steps, and we will respond to any request from such authorized agent in accordance with the CCPA.
8. Changes to this Policy