California Privacy Disclosures
Last updated December 18, 2022
These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California (“consumers” or “you”).
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 (“CCPA”). Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
For purposes of these CA Disclosures, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is de-identified or aggregated such that it is not capable of being associated with us, or that is excluded from the CCPA’s scope. This section does not apply to information relating to our employees, contractors, and other personnel.
Collection and Use of Personal Information
We collect personal information from and about you for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information and the purposes for which we use this information, please refer to the Our Collection of Personal Information and Our Use of Personal Information sections of the Privacy Notice.
In the last 12 months, we may have collected the following categories of your personal information:
- Identifiers, such as name, address, phone number, email address, or other similar identifiers;
- California customer records, such as payment information;
- Commercial information, such as records of services purchased, obtained or considered;
- Internet/Network information, such as device information, logs and analytics data;
- Geolocation data, such as approximate location data generated based on IP address or other information; and
- Inferences about interests and preferences, generated from your use of the sites.
We may collect this information directly from you, from our business partners and affiliates, from your browser or device when you visit our websites, or from third parties that you permit to share information with us.
We use this information for one or more commercial or business purposes as described in our Privacy Notice. These purposes include, without limitation:
- Auditing related to our interactions with you,
- Performing services on behalf of the business, such as providing customer service,
- Legal compliance,
- Detecting and protecting against security incidents, fraud, and illegal activity,
- Internal research, analytics, and benchmarking, and
- Other operational purposes.
In the last 12 months, we have not collected any “sensitive personal information” (as defined by the CCPA).
Retention of Personal Information
We retain personal information only for as long as is reasonably necessary to fulfil the purposes for which it was collected. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations. For example, we retain personal information for as long as the individual continues to use our services for the purposes explained in our Privacy Notice. When an individual discontinues the use of our services, we will retain their personal information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive communications they have requested. Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.
Disclosure of Personal Information
We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information for a business purpose include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) analytics providers; (vii) social networks. To learn more about how we disclose data to third parties, please refer to the Our Disclosure of Personal Information section of the Privacy Notice.
Sale of Personal Information
We do not “sell” personal information or “share” personal information for cross-context behavioral advertising as those terms are defined in the CCPA.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights (subject to certain limitations at law):
- The Right to Know any or all of the following information relating to your personal information we have collected and 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;
- The categories of personal information that we have disclosed 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 and the categories of third parties to whom the information was sold; and
- The business or commercial purposes for collecting or selling the personal information.
- The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
- The Right to Correction of personal information, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data.
- The Right to Limit Use and Disclosure of sensitive personal information to certain purposes, including to perform the services or provide the goods reasonably by an average consumer who requests those goods or services.
You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights 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 and services or engage with you in the same manner.
How to Exercise Your California Privacy Rights
You may submit a request to exercise your California Consumer Rights by calling us at 214-515-1100 or by emailing email@example.com with the subject line “California Rights Request.” We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.
In certain circumstances, California residents are permitted to use an authorized agent to submit requests to know or delete personal information on their behalf through the designated methods set forth in this Notice, where we can verify the authorized agent’s authority to act on their behalf by:
- receiving a power of attorney valid under the laws of California from the consumer or their authorized agent; or
- receiving sufficient evidence to show that the consumer has:
- provided the authorized agent signed permission to act on their behalf;
- verified the consumer’s own identity directly with us pursuant to the procedures set forth in this Notice; and
- directly confirmed with us that the consumer provided the authorized agent permission to submit the request on their behalf.