Last updated: January 1st 2020
We adopted this policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this policy.
1. Information we collect
This policy relates to the collection of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“personal information”).
The table below indicates the categories of personal information about consumers that we have collected within the last twelve (12) months. Note that the examples given below do not represent a comprehensive list. Note also that not all categories and examples shown below may apply to you.
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, address, telephone number, education, employment. Some personal information included in this category may overlap with other categories.|
|Commercial information||Records of services purchased or obtained from us, or considered, or other purchasing or consuming histories or tendencies relating to our services.|
|Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with our services and advertisements.|
|Geolocation data||A device’s physical location – to the extent that an IP address may provide information regarding the location of a device you use to access our services.|
|Professional or employment-related information||Current or past job history.|
2. Where we collect information from
3. Using your personal information
We may use or disclose your personal information for one or more of the business purposes listed below or to carry out other reasonable business purposes consistent with this list:
We may also use your personal information as described to you in a notice when collecting your information.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
4. Sharing your personal information
In the preceding twelve (12) months, we have not sold any personal information as covered by this policy.
To make our services work as intended, we may need to share your personal information with other third parties and service providers.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We may disclose your personal information for a business purpose to the following categories of third parties:
5. Your rights and choices about your personal information
The CCPA provides consumers with specific rights regarding their personal information. This section describes these rights and explains how to exercise them.
Right to know
You have the right to know what personal information we have collected about you over the past 12 months. You can request that we disclose certain information to you about our collection, use, disclosure and sale of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
There are a number of exceptions that may apply. For example, we may deny your deletion request (in whole or in part) if retaining the information is necessary for us or our service providers to:
Exercising Your CCPA Rights
To exercise your CCPA rights (the access, data portability, and deletion rights described above), please submit a verifiable consumer request to us by contacting firstname.lastname@example.org. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You will need to provide certain personal information so that we can properly verify your consumer request. We will only use the personal information provided in a verifiable consumer request to confirm the requestor’s identity or their authority to make the request.
If we cannot verify the requestor’s identity or their authority to make the request or if we cannot confirm that the personal information provided relates to the consumer which is the subject of the request, we may deny the request.
The verifiable consumer request must:
Depending on the nature of your request, we may require additional information and we will advise you of this at the time.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. 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 verifiable consumer 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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
6. Changes to Our Privacy Notice
7. How to Contact Us
If you have any questions or comments about this policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under the CCPA, please do not hesitate to contact us at email@example.com or write to us at:
FAO: Head of Privacy
160 Blackfriars Road
London SE1 8EZ