California Privacy Rights – California Consumer Privacy Act (CCPA).
The CCPA provides California residents with specific rights regarding their personal information. Each right includes the ability to make a specific consumer request and corresponding obligation of the receiving party to (i) verify the identity of the requestor and (ii) respond in accordance with CCPA guidelines. This section describes your CCPA rights and explains how to exercise those rights.Right to Request Information Regarding Personal Information Use/Disclosure and Portability.
You have the right to request a summary of the collection, use, and disclosure of your personal information over the past 12 months. In response to a verifiable request for these services, we will disclose the following information for the Properties:
- The categories, specific types, and sources of personal information we collected about you.
- Our business purpose for collecting the personal information.
- The categories of third parties with whom we share that personal information and the purpose for the disclosure.
You also have the right to request a copy of this personal information in a readily useable format that is transferable to other entities (frequently referred to as “data portability”). If you make a data portability request, the Company may be (i) restricted from providing certain sensitive personal information in response to the request or (ii) prohibited from granting the request entirely if it presents an unreasonable security risk.
Right to Request Deletion of Personal Information.
You have the right to request that the Company delete any of your personal information that we collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal information from our records, unless one of the following exceptions applies:
We may deny your deletion request if retaining the information is necessary for the Company or our service providers to:
- Complete the transaction for which we collected the personal information, provide the Properties that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug Properties to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Submitting CCPA Requests – Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to us by either:
Only you (or someone legally authorized to act on your behalf) may make a verifiable request related to your personal information. You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:
- Provide sufficient information that allows us to confirm your identity as the person about whom we collected personal information (and, if applicable, the authority and identity of an authorized representative).
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Please note, we cannot respond to your request or provide you with personal information if we cannot (i) verify your identity or authority to make the request and (ii) confirm the personal information relates to you. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
CCPA Request Responses and Timelines
We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require additional time beyond the 45 days, we are entitled to an extension up to an additional 45 days (for a total response timeline capped at 90 days). In the event that an extension is necessary, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account where possible. If you do not have an account with us, or your existing account lacks a communication feature, we will deliver our written response to your designated email address.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales – Opt Out Rights
The Company does not sell personal information collected through the Properties, and no such activity has occurred in the prior 12 months. In the event that the Company changes its practices and engages in the sale of information, we will provide advance notification to impacted individuals and offer the ability to opt in/opt out in accordance with CCPA requirements.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.