YOUR CALIFORNIA PRIVACY RIGHTS
CCPA
If you are a California resident, then under the California Consumer Privacy Act of 2018 and its implementing regulations (collectively, as it may be amended, “CCPA”), California law provides you with specific rights regarding your Personal Information (as defined under the CCPA). These involve information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household, subject to certain exclusions such as certain publicly available, aggregated, or deidentified information, and with certain exemptions such as information collected in an employment/contractor or business-to-business context. These rights include:
(a) The right to know about the processing of Personal Information collected, disclosed, and (if applicable and as defined under the CCPA) “sold” about you in the prior 12 months, including the categories and specific pieces of Personal Information collected, the business or commercial purposes for collection and disclosure, the categories of sources from which it was obtained, and the categories of parties to whom it was disclosed.
(b) The right to request the deletion of such Personal Information collected from you, subject to certain exceptions.
(c) The right not to receive discriminatory treatment for exercising your CCPA rights. Please note we will not discriminate against you because you exercise your such rights, and we do not offer any financial incentives for the collection or use of Personal Information.
(d) If the Business “sells” Personal Information (which may be for “monetary or other valuable consideration”), the right to opt-out of the “sale.” Please note we have not “sold,” and do not “sell” your Personal Information (and accordingly, do not “sell” such Personal Information respecting children under 16). This assessment is based on the definition of “sell” under the CCPA, current regulatory guidance, and current customary interpretations. Should our practices ever change in the future, then we will provide a compliant notice and method to opt out.
Requests to Know or Delete
If you are a California consumer, you or your authorized agent may request information about the Personal Information we have collected about you in the prior 12 months (as described under (a) above) or to request that we delete your information (as described under (b) above) by emailing us at info@califaces.com. In the request, please specify which right(s) you are seeking to exercise and the scope of the request. In accordance with the CCPA, we may require additional information to verify your identity (or to verify that your authorized agent has the authority to make the request on your behalf) before responding to a CCPA rights request. If we are unable to so verify, we may deny your requests. We will confirm receipt and respond to all verified requests in accordance with applicable timelines required by the CCPA.
Disclosures
For purposes of California consumers, please see the following disclosures regarding how we (including our Service Providers on our behalf) may have collected, used, and disclosed your Personal Information collected in the previous 12 months in accordance with the CCPA. This will depend on how you have interacted with us and other factors. Note: though the Service has not been operational prior to the effective date of this Privacy Policy (which coincides with its launch date), we will describe categories of Personal Information enumerated in the CCPA which may have been collected by prior means in the prior 12 months, and indicate where practices are likely to change.
The following categories of Personal Information enumerated in the CCPA may have been collected in the past 12 months from the following potential sources (as such information and sources may be more fully described in the “What May We Collect?” section above):
Identifiers, such as your name, email, mailing address, and similar identifiers.
Sources: We may have collected identifiers from: You (e.g., through direct communications), Service Providers, (e.g., social media vendors), Other Sources (e.g., social media), Business Partners (e.g., licensees), Affiliates.
Legally Protected Characteristics, such as age, gender, marital status.
Sources: Other Sources (e.g., social media), Service Providers, You (e.g., through direct communications).
Commercial information, such as purchasing histories or tendencies or consumer preferences.
Sources: Business Partners (e.g., licensees), Other Sources (e.g., social media), Affiliates, You (e.g., through direct communications).
Audio, electronic, visual, or other similar information (e.g., in any user-generated content)
Sources: Other Sources (e.g., social media), Affiliates, You (e.g., through direct communications).
Professional or employment-related information (e.g., employment status or other information shared on social media)
Sources: Other Sources (e.g., social media), You (e.g., through direct communications).
These additional categories and sources may apply to information collected in the future:
Identifiers, such as your IP address
Sources: Automatically, Service Providers
Internet or other electronic network activity, such as Usage Information as described above.
Sources: Automatically, Service Providers
Geolocation data, such as approximate general location estimated from your IP address
Sources: Automatically, Service Providers
Purposes:
In the past 12 months, any of the above categories of Personal Information collected may have been used for certain of the business and commercial purposes described in the “How May We Use It?” section above, such as Research (e.g., understanding our audience), Communications (e.g., to respond to direct requests from you), Optional Features (e.g., participation in certain activities on social media pages), and Security/Enforcement. In the future, we may use it for additional purposes such as Service Operations, and additional uses within the categories above.
Sharing:
In the past 12 months, any of the above categories of Personal Information collected may have been disclosed for business and commercial purposes described in the “How May We Share It?” section above, including Service Providers (e.g., our vendors performing services for us), Affiliates, and Law Enforcement/compliance. Future additional categories of disclosures may include the sharing of Identifiers and other information as may be required when you enter Promotions.
Note about CCPA: The above reflects our good faith understanding of the law and our data practices as of the date posted above, but the CCPA is a new law and there remain differing interpretations of it and its implementing regulations. Accordingly, we may update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.
“Shine the Light” Law
California’s “Shine the Light” law (California Civil Code Section 1798.83) permits California residents to request certain details about how certain types of their information are shared with third parties for such third parties’ own direct marketing purposes. We do not share such information in such manner, but should we ever do so in the future, we will provide California customers with such information upon request or permit them to opt in to, or opt out of, this type of sharing.
CHILDREN/MINORS
The Service is not directed to children under eighteen (18) years of age, who are prohibited from using the Service per our Terms of Use. Accordingly, we do not knowingly collect any Personal Information from them. If you believe we may have collected any from your child on the Service, please contact us at info@califaces.com and we will make reasonable efforts to delete it from our records, when required by law.
SECURITY
We take commercially reasonable steps to help protect your Personal Information against unauthorized access, disclosure, misuse, or loss. However, no data transmission or storage can be guaranteed to be 100% secure. Therefore, we cannot ensure or warrant the security of any information collected through the Service.
UPDATES/MODIFICATIONS
From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. We will provide notice to you if these changes are material and, if required by applicable law, we will obtain your consent. Notice may be provided by posting notice of such changes on the Service, by email to you at the last email address you provided us (if any), or by other means consistent with applicable law.
CONTACT US
If you have any questions about this Privacy Policy, you may email us at info@califaces.com.
