Last Updated: June 1, 2022
Scope of Disclosures
These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 efined in the CCPA. For the purpose of these CA Disclosures, personal information applies to “personal information” as defined by the CCPA (also referred to herein as “PI”).
Collection and Use of Personal Information
In the last 12 months, we may have collected the following categories of PI:
Identifiers, such as name, email address, residential address or other similar identifiers.
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birth date, contact information, and payment information.
Protected Classification Characteristics, such as age and gender.
Commercial Information, such as payment and purchase history.
Internet/Network Information, such as device information, logs and analytics data
Geolocation Information, such as precise location information from your device or generated based on IP address or Wi-Fi.
Profession/Employment Information, such as your employer or company, and payroll and tax information.
Other Personal Information, such as information you answer in a survey, other accounts that you link or otherwise provide to us.
Inferences, such as predictions about your interests and preferences.
Disclosure and Sale of Personal Information
The categories of third parties to whom we may sell or disclose for a business purpose may include: (i) other brands and affiliates; (ii) our service providers and advisors; (iii) marketing/advertising and strategic partners; (iv) analytics providers; and (v) social networks.
In the last 12 months, we may have disclosed all of the categories of PI we collect (explained above) to third parties for a business purpose.
In the last 12 months, we may have “sold” the following categories of personal information, according to your settings and your right to opt-out: (i) Identifiers, (ii) Commercial Information, (iii) Internet / Networks Information, (iv) Geolocation Information, (v) Other Personal Information and (vi) Inferences.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the PI about you that we have collected (subject to certain limitations at law):
You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity: The specific pieces of personal information we have collected about you; The categories of personal information we have collected about you; The categories of sources of the personal information we have collected about you; The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and The business or commercial purposes for collecting or, if applicable, selling personal information about you.
The Right to Request Deletion
You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).
How to Exercise Your California Privacy Rights
To exercise your right to access/know and/or right to deletion, please submit a request by
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information identified on the California Resident Rights Request Form, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to access/know and/or right to deletion, particularly where we are unable to verify your identity.
To Exercise Your Right to Opt Out of Personal Information Sales
We “sell” personal information to third parties, as such term is broadly defined under the CCPA. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.
To exercise your Right to Opt Out of Personal Information Sales, please submit a request by clicking the following link:
You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time through the Data Dividend Controls Center Data Dividend Controls Center in our App or by emailing us at email@example.com.
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these CA Disclosures where we can verify the authorized agent’s authority to act on your behalf.
For requests to access/know or delete PI, we require the following for verification purposes:
For requests to opt-out of “sales,” we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.
“Shine the Light”
California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click the “Do Not Sell My Personal Information” link above.
In addition, we may offer you financial incentives for the collection, sale, retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs, and/or their terms by posting notice on the program descriptions and terms linked to above, so check them regularly.
Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty. We calculate the value of the offer and financial incentive by using the expense related to the offer.
Updates to These CA Disclosures
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you through appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.