The California Consumer Privacy Act (“CCPA”), and its replacement the California Privacy Rights Act (“CPRA”), provide additional rights to California residents. This section addresses those rights and applies only to California residents. Any rights specifically relating to the CPRA shall not take effect until January 1, 2023.
We acknowledge that you may have rights under the CCPA/CPRA in connection with the personal information we process on behalf of our brand clients. If personal information about you has been processed by us as a service provider on behalf of a brand client and you wish to exercise any rights you have with such personal information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our brand client on whose behalf we processed your personal information. We will refer your request to that brand client, and will support them to the extent required by applicable law in responding to your request.
A. Notice of Collection.
We have collected the following categories of personal information (as described in the CCPA/CPRA) in the past 12 months. For further details on the personal information we collect and how we obtain this information, please review the “Information Collection” section above.
We collect and use this personal information for the business purposes set out in the “Use of Information” section above.
- Identifiers, including name, email address, and online identifiers (such as IP address).
- Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
- Non-precise geolocation data, including location derived from an IP address.
- Professional, employment, or education-related information.
- Inferences drawn from any of the information identified in this section.
We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above.
We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
C. Right to Know, Correct, and Delete.
You have the right to know certain details about our data practices. In particular, you may request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold or shared;
- The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
- The business or commercial purpose for collecting or selling or sharing the personal information; and
- The specific pieces of personal information we have collected about you.
Unless you specify otherwise, the response we provide will cover the 12 month period preceding our receipt of the request. Starting with personal information collected on or after January 1, 2022, you may request that we disclose details beyond the 12-month period, and we shall do so unless doing so proves impossible or would involve a disproportionate effort.
In addition, you have the right to correct (effective January 1, 2023) or delete the personal information we have collected from you.
To exercise any of these rights, please email us at email@example.com. If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
D. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
E. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
F. Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.