California Privacy Policy
Your California Privacy Rights
This section of the Notice applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.
California residents have the following rights:
- To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;
- To know the length of time we intend to retain each category of Personal Information;
- To know whether your Personal Information is sold or disclosed and to whom;
- To access your Personal Information;
- To delete the Personal Information you have provided to us, with certain exceptions;
- To correct your Personal Information;
- To opt out of the sale of Personal Information;
- To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;
- To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and
- Not to be discriminated against, even if you exercise your privacy rights.
Request for Information, Correction, or Deletion
California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:
- The categories of Personal Information collected about you;
- The categories of sources from which the Personal Information is collected;
- The business or commercial purpose for collecting, selling or sharing Personal Information;
- The categories of third parties to whom the business discloses Personal Information; and
- The specific pieces of Personal Information collected about you.
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.
Personal Information Collected
We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
| Category of Personal Information | Examples of this Category | Sources of Personal Information | Business Purpose for Collection |
| Identifiers | Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers. | You Automatically Third Parties |
To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
| Personal information described in California Civ. Code § 1798.80(e) | 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. | You Automatically Third Parties |
To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
| Characteristics of protected classifications under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or credit, marital status, medical condition (AIDS/HIV status, cancer), physical or mental disability, gender, sexual orientation, veteran or military status, genetic information, political activities or affiliations, familial status, source of income status, status as a victim of domestic violence, assault, or stalking. | N/A | N/A |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | You Automatically |
To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
| Biometric information | An individual’s genetic, physiological, biological or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA) or activity patterns that can be used to establish individual identity | N/A | N/A |
| Internet or other electronic network activity information | Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. | Automatically |
To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
| Geolocation data | Physical location and/or movements. | N/A | N/A |
| Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | You Automatically |
To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
| Professional or employment related information | Current or past job history or performance evaluations | You (For Job Applicants only) | To provide our Services To provide information you requested To verify identity To prevent fraud To comply with law To evaluate job applicants |
| Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) | Education records directly related to a student maintained by an educational institution or party acting on its behalf. | N/A | N/A |
| Inferences drawn from other Personal Information | Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | You Automatically Third Parties |
To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
| Sensitive Personal Information | Social security number, driver’s license number, account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of e-mails or texts to others, genetic/ biometric data, health information, sex life/sexual orientation data | You Third Parties (For Job Applicants only) |
To provide our Services To provide information you requested To verify identity To prevent fraud To comply with law To administer employment benefits |
Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above.
Personal Information Sold or Shared
We have sold or shared (as those terms are defined in the CCPA) to third parties the following Categories of Personal Information in the last twelve (12) months:
| Category of Personal Information | Recipient Categories | Purpose for Sale/Sharing |
| Identifiers | Advertising, marketing, and analytics providers | Marketing |
| Personal information described in California Civ. Code § 1798.80(e) | N/A | N/A |
| Characteristics of protected classifications under California or federal law | N/A | N/A |
| Commercial information | Advertising, marketing, and analytics providers | Marketing and analytics |
| Biometric information | N/A | N/A |
| Internet or other electronic network activity information | Advertising, marketing, and analytics providers | Marketing and analytics |
| Geolocation data | N/A | N/A |
| Sensory data | N/A | N/A |
| Professional or employment related information | N/A | N/A |
| Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) | N/A | N/A |
| Inferences drawn from other Personal Information | Advertising, marketing, and analytics providers | Marketing and analytics |
| Sensitive Personal Information | N/A | N/A |
We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
Personal Information Disclosed for Business Purposes
We have disclosed the following categories of Personal Information for business purposes in the last twelve (12) months:
| Category of Personal Information | Recipient Categories | Business Purpose for Disclosure |
| Identifiers | Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services |
| Personal information described in California Civ. Code § 1798.80(e) | Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services |
| Characteristics of protected classifications under California or federal law | Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services |
| Commercial information | Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services |
| Internet or other electronic network activity information | Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business I nternal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services |
| Sensory data | Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services |
| Professional or employment-related information | Service Providers |
Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services |
| Inferences drawn from other Personal Information | Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services |
Do Not Sell My Personal Information
As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information for monetary consideration, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, please click on Your Privacy Choices
Right to Limit Use of Sensitive Personal Information
California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Please note that we only keep your Sensitive Personal Information for a limited time, and only for the transaction for which it is required. Currently, we do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you as an Employee or Job Applicant.
Right Not to Be Discriminated Against
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Notice of Financial Incentives
We may offer current or potential users of our Services the opportunity to sign up to receive marketingrelated SMS/Text Message notifications about the Services. As part of these programs, you may receive a financial incentive from us, such as special promotional offers or discounts regarding the Services or subscriptions for the Services. In exchange for your participation in these programs, we may collect your Personal Information, such as your mobile phone number, name, and email address. No purchase is required to sign up for message alerts from us, although standard text messaging rates and fees (as determined by your cellular network provider) may apply. Participation in these programs is governed by this Notice and our Terms, and the terms and conditions of any additional agreements provided to you before you sign up to participate in the program. You may cancel or terminate your participation in these programs at any time by following instructions you receive in the agreements and materials that we provide to you when you sign up to participate in the program, or by calling the official customer service number provided in the “Contact Us” webpage of the Site for our publication that is sending you the SMS/Text Message notification. You may also cancel or terminate your participation in these programs by following the instructions in the SMS/Text Message notifications that you receive from us. Our good-faith estimate of the value of your Personal Information for participating in our SMS/Text Message notification programs is the value of the benefit we offer you. We have calculated such value by using the expense related to the benefit.
Third Party Marketing (“Shine The Light” law)
If you are a California resident with an established business relationship with us, you have the right under California Civil Code Section 1798.83 to request information regarding the disclosure of your Personal Information to third parties for their own direct marketing purposes in the preceding calendar year. You have the right to prevent disclosure of Personal Information, and we provide a cost-free option to exercise that right [as set forth below in “Exercising Your California Privacy Rights.”] Please include “Shine the Light Opt Out” in your request. We do not currently disclose Personal Information protected under this section to third parties for their own direct marketing purposes.
Exercising Your California Privacy Rights
You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by contacting us using the information in the Contact Us section below.
If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
