At various times, we may 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”). We may have collected the following categories of Personal Information from consumers (when applicable) within the last twelve (12) months:
|Category of Personal Information||Examples|
|Identifiers||A real name, alias, postal address, unique personal identifiers (such as device identifiers, internet protocol address, cookies, beacons, pixel tags mobile ad identifiers or similar technology, customer numbers, unique pseudonyms, user aliases, telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular customer or device), online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.|
|Personal Information categories listed under the California Customer Records statute||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. Please note that some categories of Personal Information under this statute may also be included in other categories of Personal Information.|
|Characteristics of protected classes under California or federal law||Age (if 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).|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|Biometric information||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, and sleep, health, or exercise data.|
|Internet or other similar network activity||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.|
|Geolocation data||Tracking of physical location or movements.|
|Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.|
|Professional or employment-related information.||Current or past job history or performance evaluations.|
|Non-public education information||Education records directly related to a student that are 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.|
|Inferences drawn from other Personal Information||Creation of a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
This Policy does not address the following categories of Personal Information which are not covered by CCPA:
We obtain the categories of Personal Information listed above from the following categories of sources:
We may use or disclose the Personal Information we collect for one or more of the following business purposes and commercial purposes:
We may disclose or sell your Personal Information to a third party for a business or commercial purpose. In the preceding twelve (12) months, we may have disclosed or sold the following categories of Personal Information for a business purpose or a commercial purpose:
We share Personal Information with the following categories of third parties:
As disclosed above, we and our advertising partners may collect Personal Information (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site (or use our app). We, and our partners, use this Personal Information to tailor and deliver ads to you on our site (or app), or to help tailor ads to you when you visit others' sites (or use others' apps). To tailor ads that may be more relevant to you, we and/or our partners may share the information we collect with third parties.
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes those CCPA rights and explains how to exercise those CCPA rights.
You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Subject to certain exceptions, you have the right to request that we delete the Personal Information that we collected about you. Once we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records subject to certain exceptions. In the event that we are unable to honor a request, we will inform you of the reasons behind the decision.
In the event that we sell your Personal Information, you have the right to submit a request to opt-out of the sale of your Personal Information. You may also choose to opt-out of the sales of certain categories of Personal Information, should you choose. You may later choose to permit us to sell your Personal Information.
In the event that we sell your Personal Information and if you do not wish for us to sell your Personal Information to third parties for advertising purposes (if we sell your Personal Information), select the applicable control from the “Do Not Sell My Personal Information” link provided. After opting out, we may continue to share some Personal Information with our partners (who will function as our service providers in such instance) to help us perform advertising-related functions such as, but not limited to, measuring the effectiveness of our ads, managing how many times you may see an ad, reporting on the performance of our ads, ensuring services are working correctly and securely, providing aggregate statistics and analytics, improving when and where you may see ads and/or reducing ad fraud. If you access this site (or app) from other devices or browsers, visit the link below from those devices or browsers to ensure your choice applies to the Personal Information collected when you use those devices or browsers.
Additionally, although clicking the “Do Not Sell My Personal Information” link will opt you out of the sale of your Personal Information for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Information (except for Personal Information sold within 90 days prior to your exercising your right to opt out) or all interest-based advertising. If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You have a right to not receive discriminatory treatment for exercising your CCPA rights. We respect your rights and we will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights.
Notice of Financial Incentive
We do not offer any financial incentive, benefit, or price differences in return for the disclosure, deletion, or sale of Personal Information.
To exercise the CCPA consumer rights described above, please submit a verifiable consumer request to us by either:
In order to protect your Personal Information, please note that:
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. Although you may use an authorized agent to submit a request to opt-out on your behalf, we may deny a request from an authorized agent that does not submit proof with the request that they have been authorized by you to act on the consumer’s behalf.
It is important to know that you are not required to create an account with us to make a verifiable request. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response through our web portal. Any disclosures we provide will only cover the 12-month period preceding your verifiable request's receipt. For data portability requests, we will select an industry-acceptable format to provide your Personal Information.
Unless a request is manifestly unfounded or excessive, we will not charge a fee to process or respond to your verifiable consumer request. If we determine that a request is manifestly unfounded or excessive, we will tell you why we made that decision and reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request.
Last Updated: December 2019