Last Revised: xx/xx/2021
Definitions Specific to this Policy
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include publicly available information obtained from government records, deidentified or aggregated consumer information that cannot be reconstructed to identify you, or certain information governed by existing federal laws.
“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by us to another business or a third party for monetary or other valuable consideration.
“Service Provider” means for-profit entity that processes information on our behalf and to which we disclose Personal Information for a business purpose pursuant to a written contract.
“Third Party” means a person or entity, other than a Service Provider, that collects Personal Information on our behalf or receives it from us.
The Personal Information We Collect and Disclose
The chart below shows the categories of Personal Information we collect; examples of the type of Personal Information in each category; the types of sources from which each category of Personal Information is collected; the business purpose(s) for which that category of Personal Information is collected; and the types of third parties with whom that category of Personal Information is shared. As this chart shows, we disclose certain Personal Information to Service Providers and third parties for business and commercial purposes. We do not sell the personal information of minors under 16 years old without affirmative authorization. This information covers the past 12 months.
|Categories of Personal Information||Description or Examples||Sources of Personal Information||Business Purpose(s) for Collection||Third-Party Recipient(s) of Personal Information that is Shared or Sold (indicated by italics)|
|Unique identifiers||Name, signature, address, telephone email, account name, SSN, driver’s license number, passport number, online identifier, IP address|
|Government ID number||Social Security number, passport number, driver’s license or state identification card number|
|Physical description||Physical characteristics or description|
|Financial information||Bank account number, credit card number, debit card number, or any other financial information|
|Health/medical information||Medical information or health insurance information|
|Insurance information||Insurance policy number or health insurance information|
|Protected class data||Characteristics of protected classifications under California or federal law, including race, ancestry, national origin, age (40 years or older), marital status, sex, sexual orientation, medical condition, disability, genetics, and veteran or military status|
|Purchase history||Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies|
|Biometric data||Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings,
faceprint, voiceprint, keystroke patterns or rhythms, gait
patterns or rhythms, and sleep, health, or exercise data
|Internet activity||Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement|
|Geolocation data||Longitude and latitude coordinates or other precise geolocation information|
|Audio, visual, olfactory information||Audio, electronic, visual, thermal, olfactory, or similar information|
|Employment information||Professional or employment-related information|
|Education information||Personally-identifiable education information that is not publicly available (e.g. grades or financial aid)|
|Inferences||Inferences drawn from collected information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes|
We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.
Access to Your Personal Information
You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if that is the case.
- Categories of Personal Information Collected
Deletion of Your Personal Information
You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
- If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, click [here] or call [toll-free no]. The link will take you to an interactive webform that you can complete and submit to make a request for deletion that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
Right to Opt-Out
You have the right to request that we not sell Personal Information that we have collected. If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions.
- If you would like to request that we not sell your Personal Information pursuant to the requirements of the CCPA, click [here] or call [toll-free no]. The link will take you to an interactive webform that you can complete and submit to make a request for deletion; if you use the telephone number, you will be guided through a process that will allow you to submit a request.
- If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that the agent has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.
If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell your Personal Information.
You have the right to opt-in to the sale of your Personal Information after you have opted out. If you would like to opt-in to the sale of your Personal Information, click [here] or call [toll-free no]. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.
Financial Incentives and Non-Discrimination
However, we may provide financial incentives to consumers who allow us to retain and disclose their Personal Information. These incentives may include payments to consumers, a lower price for goods or services, and/or a higher level of goods or services.
The incentive[s] we provide is/are as follows:
- [short summary of incentive, including material terms]
- [categories of personal information implicated by incentive]
- You may withdraw from the incentive at any time. If you have previously opted-in to the incentive below and wish to opt-out, click [here]
To opt-in to the incentive, click [here]
Our incentive is permissible under the CCPA because [description of how the financial incentive is reasonably related to the value of the consumer data]. We estimate that value at $_____, and we arrived at that figure by ___________________.]
You may designate an authorized agent to exercise your rights under the CCPA on your behalf.
Pursuant to the CCPA:
- Only an individual with power of attorney, or a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
- We may require that you or the authorized agent do the following:
Provide proof of your signed written permission for the authorized agent to submit a request on your behalf – We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
Verify your identity with us directly – This does not apply if you have provided a valid power of attorney to the authorized agent.
Personal Information of Minors [Choose one of the two options below]
[ We do not sell the Personal Information of minors who are at least 13 years old and less than 16 years old unless those individuals have opted in to the sale of their Personal Information. To opt in, such a minor must first clearly request to opt in via the link below, after which the minor will be required to separately confirm that election. As part of that confirmation process, the minor will be informed that he or she has the right to opt out at a later date and what the process is for doing so.
We do not sell the Personal Information of minors who are under 13 years old unless a parent or guardian of that minor affirmatively authorizes the sale of that Personal Information. We verify that the individual making such an authorization is the minor’s parent or guardian by _________________________ [examples of appropriate verifications in this circumstance are listed in CCPA regulation §§ 999.330(a)(2)(a)-(f)]. As part of that verification process, the parent or guardian will be informed that he or she may opt out on behalf of the minor at a later date and what the process is for doing so.
[ Our websites and mobile applications are not intended for children or minors under 16 years old. Accordingly, we do not store information from minors under 16 years old. If you believe that a child has submitted Personal Information to us, please contact us at [insert email].]
Personal Information Metrics
|Type of Request||Number received||Number complied with (in whole or in part)||Number denied||Median [Mean] number of days to provide a substantive response|
|Request to Know|
|Request to Delete|
|Request to Opt-Out|
The above information is for the prior calendar year.
Additional California Privacy Rights
California Civil Code Section § 1798.83 permits users of our website who are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to [insert email ] with the subject “Shine the Light Request.”