California Privacy Act
Effective: January 1, 2020
How we collect, use and share CCPA information
We collect CCPA Information about you in several different ways. For example, we collect information directly from you when you sign up as a guest user of our mobile application. We and service providers working on our behalf collect information from you when you use one of our websites, mobile apps, view our emails or otherwise engage with us through a computer or mobile device. We also collect personal information about you from third parties such as service providers, marketing companies and data providers.
We use your CCPA Information for business purposes including to market our products and services, to provide services such as our mobile application, and to perform analytics and research to improve and develop our websites, mobile apps, services and products.
We do not sell your CCPA Information, or any other personal information that we collect about you. We may share your CCPA Information with third parties for business purposes or as permitted or required by law including with service providers that provide marketing and advertising or other communications services, or that perform analytics and research to improve and develop our websites, mobile apps, services and products.
The following are the categories of CCPA Information we have collected and shared within the past 12 months, and examples of certain kinds of information that may fall into those categories.
|PERSONAL IDENTIFIERS||Name, postal address, email address, unique personal identifier.|
|OTHER IDENTIFYING INFORMATION||Phone number, date of birth, family member information.|
|CHARACTERISTICS OF PROTECTED CLASS||Age, ancestry, religion or creed, marital status, gender, veteran or military status.|
|COMMERCIAL INFORMATION||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY INFORMATION||Information regarding your interaction with our website, application or advertisements, links you use or web pages you visit while visiting our site or applications, browser type, internet service provider (ISP), cookies, and mobile device including device identifier or other device information, and location information.|
|GEOLOCATION DATA||Physical location, movements, or trip tracking information.|
|EMPLOYMENT INFORMATION||Professional or employment-related information.|
|INFERENCES||Inferences drawn from personal information to create a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities or aptitudes.|
California consumer privacy act rights and choices
Right to Access CCPA Information: You have the right to request that we disclose certain information about our collection and use of CCPA Information about you over the past 12 months, including:
- the categories of CCPA Information collected about you,
- the categories of sources from which CCPA Information about you was collected,
- the business purpose for collecting CCPA Information about you,
- the categories of third parties with whom we have shared CCPA Information about you, and
- the specific pieces of CCPA Information we have about you.
Right to Deletion of CCPA Information: You have the right to request that we delete CCPA Information we have collected from you, subject to certain exceptions. In response to a request, we will delete CCPA Information we have collected from you unless the CCPA Information is needed for the following:
- To complete a transaction for which we collected the CCPA Information, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you,
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities,
- Debug products to identify or repair errors that impair functionality,
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law,
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us,
- Comply with a legal obligation, including compliance with the California Electronic Communications Privacy Act, or
- Otherwise use CCPA Information about you, internally, in a lawful manner that is compatible with the context in which you provided the information.
To better protect you and CCPA Information about you, we will only respond to access or deletion requests that we have been able to properly verify through our authentication processes. To verify your identity, you will be asked to provide certain information, which we will only use to verify your identity and/or your authority to make the request. Responses to verified requests may take up to 45 calendar days or longer depending on the nature of the request. If additional time is needed, we will notify you. We will not respond to more than two access requests from you within a 12-month period.
Non-Discrimination Rights: We will not discriminate against you for exercising any of your rights under the CCPA.