Last Revised: January 31st, 2022
Any terms defined in the California Consumer Privacy Act (“CCPA”) have the same meaning when used in this California Specific Privacy Notice. California residents with disabilities may access this notice in an alternative format by emailing us at (email@example.com).
Company will continue to revise our California Specific Privacy Notice to reflect the development of the CCPA and our understanding as to how it relates to our data practices.
- Use of The Site By Minors:
- Information We May Collect From You:
We collect 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 or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, email address, unique personal or online identifier,
IP address, account name, Social Security number driver’s license number, passport number, date of birth or other similar identifiers.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A 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 number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age, 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).
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|E. Biometric information.||Physiological, behavioral and biological characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity or other identifier or identifying information, such as, fingerprints, or and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
|F. Internet or other network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|G. Geolocation data.||Physical location.
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.
|I. Professional or employment-related information.
|Current or past job history or performance evaluations.
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.
|K. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
- What Personal Information Do We Collect About You, For What Purpose And On What Ground We Process It:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
- Registration information. You do not need to create an account to visit the Website, or to look at available Content, but you will need to create an account to access the full functionality of the Website. To create a Company account, you must provide some Personal Information, including your email address and a password. To complete a purchase you must include your first and last name, your billing address and credit card information. For any physical goods that we may sell through the Website, we require a shipping address as well. We may use your registration information for internal and service-related purposes, including to enable our vendors and suppliers to allow us to offer the Website, to conduct audits, research and analysis to maintain, protect, and improve the Website, or to develop new services. Except as otherwise specified in this California Specific Privacy Notice, we do not rent, sell, or share your registration information with other people or nonaffiliated companies for marketing purposes.
- Payment Information. To make purchases on the Website, you must enter valid credit card information or valid PayPal account information. We use this information only to process payments, and do not share this information with any third parties other than to process payments. When you provide payment information, it is protected so that only the payment processor stores credit card information. Please note that our payment processors’ use of your Personal Information is governed by their own policies and procedures.
- Communicating with you. We will typically communicate with you using your registered email address. If we cannot reach you by email, we may use other contact information that you provide. We will communicate with you in accordance with your preferences and in response to inquiries, to provide requested services and to manage your account. We will send you mandatory service-related announcements and notifications by email when necessary. You cannot opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option of canceling your account. We may broadcast or otherwise distribute important messages to all users or send individual messages to specific users where we have appropriate contact information to do so. We also may send information to you by email about our services, including special alerts, offers, awards, surveys, contests, promotions and updates. You will be given the option not to receive these types of communications.
- Surveys and Contests. We may provide you the opportunity to participate in contests or surveys from time to time. Participation in contests or surveys is completely voluntary. If you choose to participate, we may request certain additional information about you. We may use this information to monitor system traffic, supplement, amend and personalize our system, direct advertisements, communicate with participants, develop our products and services, or conduct market research. We will use email addresses to distribute and collect surveys, notify contest winners and award prizes.
- Legal sharing for protection of us, you, and others. We may disclose Personal Information to third parties who are assisting us in protecting against or preventing actual or potential fraud, unauthorized transactions, claims or other liabilities, or to investigate potential fraudulent or questionable activities. We may disclose Personal Information in response to legal process, such as in response to a court order or a subpoena. We may disclose Personal Information in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities or suspected fraud, violations of our Terms, or as we believe may be otherwise required by law. We may also disclose Personal Information to protect our rights or interests or the rights or interests of others.
- Merger or sale. If all or substantially all of Company or its assets are sold or transferred, your Personal Information and other information we have collected may be treated as an asset and transferred in accordance with this California Specific Privacy Notice.
- Non-private or non-Personal Information. We may share or disclose your non-private, aggregated, or otherwise non-Personal Information, such as information you publicly share, the number of users that viewed your posts, Log Data, etc.
- We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
- Sensitive Data. We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
- We require your explicit consent for processing sensitive data, so if you submit your details (i.e. any sensitive data), we will send you a further communication asking for you to confirm your consent to this processing.
- Where we are required to collect Personal Information by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
- We will only use your Personal Information for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at firstname.lastname@example.org. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
- We may process your Personal Information without your knowledge or consent where this is required or permitted by law.
- We do not carry out automated decision making or any type of automated profiling.
- We Share Information With:
- other entities within Company, where such disclosure is necessary to provide our services to our clients, to manage our contractual relationships or to manage our business;
- contractors and third-party service providers, where the disclosure is for one of the purposes connected with the collection of the information or is directly related to the purposes for which the information was obtained;
- professional advisors, including accountants, auditors, lawyers and advisors in connection with the administration, processing and servicing of client transactions;
- other persons where required or provided for by applicable laws;
- government agencies, enforcement agencies or regulators as authorized or required by applicable law, and to comply with requests of law enforcement, regulatory and other governmental agencies including tax institutions;
- in the event that the safety of our users is threatened, and we are able to do something about that by sharing Personal Information with third parties, we reserve the right to do so. This may be done to prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our Website, to help protect the security or integrity of our Website, or to enable us to take precautions against liability;
- anyone authorized by you to receive, use or access your Personal Information;
- if, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets and professional advisors providing services to us;
- we make available services such as blogs, message boards and chat functionality to which you are able to post information and materials. Please note that any information you disclose through such services or otherwise on the Website becomes public information and may be available to visitors to the Website and to the general public. In addition, when you choose to make a posting on such services certain Personal Information will be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose Personal Information about you, or any other information, on the Website. WE ARE NOT RESPONSIBLE FOR THE USE BY ANY THIRD-PARTY OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH ANY SUCH SERVICES OR OTHERWISE ON THE WEBSITE; and
- the contractors and service providers who may receive your Personal Information include those handling mailings on our behalf, external data storage and computer system maintenance or payment gateway systems. However, we will take all reasonable steps to ensure that they protect the Personal Information in the same way that we do, including by generally imposing contractual obligations on contractors and service providers selected by us to implement measures to maintain the security, confidentiality and integrity of personal information.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Clear gifs (Web beacons). We may use a software technology called clear gifs (a.k.a. web beacons), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on your hard drive, clear gifs are embedded invisibly on web pages. We tie the information gathered by clear gifs to personally identifiable information you submit while you are on the system. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
Log Data. Our servers may automatically record information (“Log Data”) created by your use of the Website. Log Data may include information such as your IP address, browser type, the referring domain, pages visited, your mobile carrier, device and application IDs, and search terms. Other actions, such as interactions with our website, applications and advertisements, may also be included in Log Data.
Personalization of Experience. We may personalize your experience by using your site behavior to shape any recommendations we may make about merchandise or content (including advertising) that might be of interest to you. We also monitor customer traffic patterns and Site and application and advertisement usage to help us develop the design and layout of the Site.
- Your Right to Access to Specific Information and Data Portability Rights:
You have the right to request that we disclose certain information about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
a. The categories of Personal Information we collected about you.
b. The categories of sources for the Personal Information we collected about you.
c. Our business or commercial purpose for collecting or selling that Personal Information.
d. The categories of third parties with whom we share that Personal Information.
e. The specific pieces of Personal Information we collected about you (also called a data portability request).
f. If we sold or disclosed your Personal Information for a business purpose, a separate list disclosing:
i. sales, identifying the Personal Information categories that each category of recipient purchased; and
ii. disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- Please note that we do not sell your Personal Information.
- Deletion Request Rights:
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. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
You may object to Company using your Personal Information for the above purposes at any time by emailing us at: email@example.com. If you do so, Company will cease using your Personal Information for the above purposes (i.e., under a legitimate interest set out above) and remove it from its systems unless such Personal Information is permitted to be used by Company for another purpose set out in this California Specific Privacy Notice or Company determines and demonstrates a compelling legitimate interest to continue in processing your Personal Information.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
a. 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.
b. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
c. Debug products to identify and repair errors that impair existing intended functionality.
d. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
e. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
f. 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.
g. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
h. Comply with a legal obligation.
i. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Exercising Access, Data Portability and Deletion Rights:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Visiting the [CCPA Request Form];
- Calling us at +1 (914) 709-5013; or
- Emailing us at firstname.lastname@example.org.
Regarding our marketing materials, you may also withdraw your consent at any time by clicking on the “unsubscribe” link at the bottom of each email or by emailing email@example.com. If an individual withdraws their consent to receiving marketing emails, we will still be able to send them essential service communications that are necessary for the performance of our services.
- Authorized Agents:
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 if you provide the authorized agent written permission signed by you or pursuant to a valid Power of Attorney. You may also make a verifiable consumer request on behalf of your minor child. When you use an authorized agent to submit a request, we may require you to:
a. Provide the authorized agent signed permission to do so.
b. Verify their own identity directly with the business.
c. Directly confirm with the business that they provided the authorized agent permission to submit the request.
- Verifiable Consumer Requests:
The verifiable consumer request must:
a. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. This may include requesting that you provide us with at least two or more pieces of Personal Information to match against Personal Information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.
b. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
- Response Timing and Format:
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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.
- Sale of Personal Information:
We do not sell your Personal Information.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
a. Deny you products or services.
b. Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.
c. Provide you a different level or quality of products or services.
d. Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
- Changes to This California Specific Privacy Notice:
We may, in our sole discretion, modify or revise this California Specific Privacy Notice at any time. Such changes or updates are effective immediately after we give notice of the change or update, which we may do so by revising the Last Revised date at the top of the California Specific Privacy Notice or by otherwise posting on the Website, by email, conventional mail and/or by any other means that provides reasonable notice. If you are subscribed to one of our mailings, you must provide us with your correct email address and make sure that email from us is not filtered from your inbox by your ISP or email software. You agree that your use of the Website, after the date such notice is posted, means that you accept and agree to be bound by such modifications or revisions to the California Specific Privacy Notice. You agree that we shall not be liable to you for any damages that might result from any changes to this California Specific Privacy Notice, if any.
- Contact Us:
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to firstname.lastname@example.org.
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