Last Updated: February 09, 2023
Table of Contents
- Definition of Personal Information
- California “Shine the Light” Law
- CCPA Disclosures and Rights; Do Not Sell
- California Do Not Track Disclosure
- Do We Use “Cookies”?
- Third Party Links
- Contact Us
1. Definition of Personal Information
Personal Information does not include:
- Information that is lawfully made available from government records.
- Information that we have a reasonable basis to believe is lawfully made available to the general public by a consumer or from widely distributed media, or information made available by a person to whom a consumer disclosed the information if the consumer has not restricted the information to a specific audience.
- Lawfully obtained, truthful information that is a matter of public concern.
- De-identified or aggregated consumer information.
- Other information excluded from the CCPA’s scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
2. California “Shine the Light” Law/Your California Privacy Rights
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits consumers who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, contact us as provided in the “Contact Us” section below.
3.1 Personal Information We Collect
We may have collected Personal Information in the following categories from consumers within the last twelve (12) months. The categories and examples provided in the chart below are those defined in the CCPA. This does not mean that all examples of that categorythe categories of Personal Information were in fact collected about you but reflects our good faith belief to the best of our knowledge that some of that all of the categories of Personal information Information may that we have been collected about consumers in the last twelve (12) months. We will update this disclosure from time to time as appropriate through the process described in Section 9 below.
|A name, alias, postal address, unique personal identifier, online identifier, username, password, social media login information, social media profile information, social media contacts, photos, videos, friends or followers, date of birth, preferences for communications, communications and opinions in chat rooms, message boards, forums, surveys, polls and online forms, other data received from social media platforms or other software (for example, from your contacts, calendar, photos or videos on your mobile devices), Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
|A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.
|Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
|D. Commercial information.
|Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
|F. Internet or other similar network activity.
|Browsing history, search history, information on a consumer’s interaction with a website, application, social media platform, or advertisement, type of computer, web browser information, search engine used, operating system, movement and activity within the website, mobile device information, including the type of device, operating system version, and the device identifier (or “UDID”), and mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.
|G. Geolocation data.
|Physical location or movements, including your geo-location (such as through our mobile app).
|H. Sensory data.
|Audio, electronic, visual, thermal, olfactory, or similar information.
|I. Professional or employment-related information.
|Current or past job history or performance evaluations.
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
|Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
|K. Inferences drawn from other personal information.
|Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We also collect user experience recordings , which reproduce your interactions with the Websites or Services, including mouse movements, page scrolling, and information you type (including Personal Information), screen taps, and other actions you take while using the Websites or Services. Recordings may include technical and usage data, as well as visual representations of actions you take while using the Websites or Services. We use these recordings to help us understand how users interact with our Websites or Services and to design a better user experience for you. You consent to our collection and use of user experience recordings. We also collect Sensitive Personal Information. By “Sensitive Personal Information ” we mean Personal Information that is not publicly available and reveals one or more of the following:
- A consumer’s Social Security, driver’s license, state identification card, or passport number;
- A consumer’s account log-in, financial account, debit card or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- A consumer’s precise geolocation;
- A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
- The contents of a consumer’s mail, email, and text messages unless we are the intended recipient of the communication;
- A consumer’s genetic or biometric data; or
- Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.
3.2 Sources of Personal Information
- Directly from you. For example, during account registration from forms you complete, subscriptions you purchase or comments you provide on our Websites.
- Indirectly from you. For example, from observing your actions on our Website or, with your consent, from your mobile device’s camera, location services (GPS), microphone, or contacts.
- From third parties. For example, third party social networking providers and advertising companies, our affiliates and service providers who provide services or information to us. If you do not want us to collect information from social networks, you should review and adjust your privacy settings on those networks as desired before linking or connecting them to our Websites.
- From publicly available sources. For example, online database searches.
3.3 Sale, Sharing, and Disclosure of Personal Information
We may have “sold” or “sell” Personal Information in the following categories from consumers within the last twelve (12) months. By sold we mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to another business or a third party for monetary or other valuable consideration.
When we disclose that we may have sold Personal Information, it means that we may have received some kind of benefit to our company in return for sharing Personal Information, but not necessarily received any money in exchange.
The categories below are those defined in the CCPA. This does not mean that all of the following categories of Personal Information about you were in fact sold but reflects all of the categories of Personal Information that we have sold in the last 12 months. We will update this disclosure from time to time as appropriate.
Categories of Personal Information Sold
B. Personal information categories listed in the California Customer Records statute.
C. Protected classification characteristics under California or federal law.
D. Commercial information.
F. Internet or other similar network activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information.
K. Inferences drawn from other personal information.
L .Sensitive Personal Information
“Sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to a third party for Cross-context Behavioral Advertising, whether or not for monetary or other valuable consideration. “Cross-context Behavioral Advertising” means the targeting of advertising to a consumer based on that consumer’s Personal Information obtained from activity across businesses or distinctly-branded websites, applications, or services, other than the business or distinctly-branded website, application, or service with which the consumer intentionally interacts. In other words, if we send you an ad based solely on your interaction with us or our Services, this is not Cross-context Behavioral Advertising.
Categories of Personal Information Shared
B. Internet or other similar network activity.
C. Sensitive Personal Information
3.4 Use of Personal Information for Business Purposes or Commercial Purposes
We may use, sell, share, or disclose Personal Information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples.
(a) Auditing Interactions with Consumers. For example: monitoring traffic to our Websites, counting ad impressions, and auditing legal and regulatory compliance.
(b) Security and Legal Compliance. For example, maintaining the safety, security, and integrity of our Website, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.
(c) Debugging/Repair. For example, identifying and repairing errors in our Websites’ functionality.
(d) Certain Short-term Uses. For example, ad customization that does not involve or contribute to profiling.
(e) Providing our Websites and Performing Services. For example, fulfilling the reason you provided Personal Information, creating, maintaining, customizing and securing your account with us, processing your purchases, transactions, and payments, hosting our Websites, providing the Services, fulfilling subscription orders, fulfilling a contract with you or comply with our Terms of Service, managing databases, performing analyses, billing, and marketing services such as managing promotions and contests.
(f) Internal Research for Tech Development. For example, testing, research, analysis, and product development, including to develop and improve our Website, products, and Services.
(g) Quality and Safety Maintenance and Verification. For example, improving, upgrading or enhancing our products, Services or Websites, and verifying the quality or safety of our Websites or Services.
(h) To respond to your inquiries and provide you with requested information and other communications, including by email or text messages, and including alerts, notification of promotions, newsletters, contests, and events.
(i) To manage, improve and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners.
(j) For marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and other third parties, provided that you have not already opted-out of receiving such communications
(k) To facilitate Cross-context Behavioral Advertising and other personalized content.
(l) To respond to your requests under the CCPA.
(m) For any other purpose described to you when we collect your Personal Information.
(n) Other Commercial Purposes. For example, to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information we hold is among the assets transferred.
(o) For any other acceptable purposes under the CCPA.
Additionally, we may use, sell, share, or disclose Sensitive Personal Information we collect for business purposes or commercial purposes, which may include the following examples.
3.5 Disclosing Personal Information to Other Parties
We may disclose your Personal Information to the following categories of other parties for a business purpose or commercial purpose, as those terms are defined in the CCPA:
- Our affiliates
- Service providers or contractors (as each are defined in the CCPA)
- Advertisers, advertising technology companies, analytics companies and other third parties (as defined in the CCPA) with whom we have business relationships
- Government regulators
- Our legal advisors and parties involved in a legal process
- To an entity involved in the sale of all or part of our business
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or Services we provide to you
When we disclose Personal Information for a business purpose, we enter into an agreement with the receiving party that describes the purpose for disclosing the Personal Information, and that requires the receiving party to keep that Personal Information confidential. Our service providers are obligated not to use the Personal Information for any purpose other than performing the services according to their agreement with us. Our contractors are obligated not to use the Personal Information for any purpose unrelated to the business purpose for which we’ve engaged them.
3.6 Retention of Personal Information
We retain each category of your Personal Information for no longer than is reasonably necessary for one or more business purposes, subject to your right to request we delete your Personal Information. It is not possible for us to predict the length of time that we intend to retain your Personal Information. Instead, we use the following criteria to determine whether it remains reasonably necessary to retain your Personal Information for one or more disclosed business purposes:
- retention required by, or as necessary to comply with, applicable law or contractual obligations;
- pendency of any actual or threatened litigation;
- pendency of applicable statutes of limitations for potential legal claims; and
- generally accepted best practices in our industry.
When we determine that it is no longer reasonably necessary to retain your Personal Information for one or more disclosed business purposes based on the above criteria, we will delete your Personal Information.
3.7 Your CCPA Privacy Rights and Choices
The CCPA provides California residents with specific rights regarding their Personal Information as described below.
(a) Right to Know about Personal Information Collected, “Sold” or Shared
You have the right to request that we disclose certain information to you about our collection, use, disclosure, sharing, and sale of your Personal Information over the past 12 months. After we receive and confirm your verifiable consumer request, we will disclose to you within the time required by the CCPA, the relevant information, which may include:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting, sharing, or selling that Personal Information.
- The categories of third parties with whom we disclose that Personal Information.
- If we sold, shared, or disclosed your Personal Information for a business purpose, two separate lists disclosing:
(i) for sharing or sales, the Personal Information categories that each category of recipient received; and
(ii) for disclosures for a business purpose, the Personal Information categories that each category of recipient obtained.
You also have the right to request a copy of your Personal Information or that we transmit your Personal Information to another entity. To the extent technically feasible, we will comply with your request and provide and/or transmit your Personal Information in a structured, commonly used, machine-readable format.
(b) Right to Request Deletion of Personal Information
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions, including if we or our service providers or contractors need the Personal Information for a reason related to our business, such as:
(1) completing the transaction for which we collected your Personal Information, providing Services that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise performing our contract with you;
(2) detecting and resolving issues related to security, security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities;
(3) debugging Websites and Services to identify and repair errors that impair existing or intended functionality;
(4) complying with legal obligations, including the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
(5) engaging 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 achievement of such research, if you previously provided informed consent;
(6) exercising free speech or ensuring another’s exercise of free speech or another right provided for by law;
(7) using the information for internal purposes that a consumer might reasonably expect based on a consumer’s relationship with us; or
(8) making other internal and lawful uses of that Personal Information that are compatible with the context in which a consumer provided it.
Please be aware that it may be a functional necessity for our Websites or Services to have Personal Information about you in order to operate, and we may not be able to provide some or all of our Websites or Services to you if you direct us to delete your Personal Information.
After we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records within the time period required by the CCPA, unless an exception applies.
(c) Right to Update Personal Information
You also have the right to request that we correct any of your Personal Information that is inaccurate by submitting a verifiable consumer request. We will correct any inaccurate Personal Information pursuant to your request to the extent possible using commercially reasonable efforts. We may deny your correction request if the Personal Information is accurate. We may also delete your Personal Information instead of correcting it to the extent such deletion would not negatively impact you.
(d) Right to Limit Use and Disclosure of Sensitive Information
You also have the right to request that we limit the use, sale, or sharing of Sensitive Personal Information by submitting a verifiable consumer request. If you submit such a request, we may continue to use or disclose your Sensitive Personal Information to:
- Complete the transaction for which we collected your Personal Information, provide goods or services 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;
- Use in a short-term and transient manner, including, but not limited to, to facilitate non-personalized advertising shown as part of your current interaction with the Services, but not including disclosure to third parties or use outside your current interaction with the Services;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
- Make any other uses of that information that are permitted by the CCPA and its implementing regulations.
3.6.1 Exercising Your Rights
To exercise the rights described Section 3.6 above, please submit a verifiable consumer request to us using the methods set forth in the Contact Us section below.
You may only make a verifiable consumer request for information or data portability twice within a 12-month period.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the Personal Information in question.
We cannot comply with your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
3.7.2 Response Timing and Format
We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to an additional forty-five (45) days), we will inform you of the reason and the needed extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, you may elect to have us deliver our written response by email or postal mail.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. However, if you specifically request disclosure beyond such 12-month period, we will process your request with respect to Personal Information we have collected during the time period you specify, provided that (a) the earliest date that your request may apply to is January 1, 2022, and (b) processing your request does not require disproportionate effort.
If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable. For data portability requests, we will select a commercially reasonable format to provide your Personal Information that is commonly useable and should allow you to transmit the information from one entity to another entity without hindrance, but we do not guarantee that all formats are useable in all media.
We do not charge a fee to process or respond to your verifiable consumer 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
3.7.3 Non-Discrimination for the Exercise of CCPA Privacy Rights
We will not discriminate against you for exercising any of your CCPA rights. In particular, we will not:
- Deny you goods or services
- Charge you different prices for goods or services, whether through denying benefits or imposing penalties
- Provide you with a different level or quality of goods or services or
- Threaten you with any of the above
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
We currently do not offer any financial incentive, benefit, or price differences in return for the disclosure, deletion, or sale of Personal Information. However, in general, our business model is based on providing a certain amount of monthly free content to readers, after which we may require that additional content access must be paid for. On some of our Websites and Services, this content may be paid for either through the delivery of advertisements, or through subscriptions. On those Websites and Services, consumers who use ad-blocking technology will be notified of the option to turn off the ad blocking or to pay for a subscription to access the content. On some other Websites and Services, content must be paid for after a certain number of monthly free articles, whether advertising is present or not.
3.8 Do Not Sell or Share My Personal Information
The CCPA requires businesses to provide a web page where consumers can opt out of the sale or sharing of their Personal Information. The link to our Do Not Sell web form is located here.
In addition, you may opt out of certain interest-based advertising by using the following resources:
(a) You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.
(b) You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.
(c) You may opt-out of having your activity on our Websites and Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.
4. California Do Not Track Disclosures
5. Do We Use “Cookies”?
Yes. Cookies and similar technologies are small files that a website or its service provider transfers to a computer’s hard drive through a Web browser (if the user allows) that enables the website’s or service provider’s systems to recognize the user’s browser and capture and remember certain information.
We use commercially reasonable procedures and various technical, administrative and physical safeguards to help protect the confidentiality of Personal Information. However, no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure given the reality of communication via technology systems. Therefore, although we believe the measures implemented by us are commercially reasonable and reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications sent to us over those systems will always remain private or secure. We are not responsible for the circumvention of any privacy settings or security features.
If you believe that your Personal Information has been accessed or acquired by an unauthorized person, please promptly Contact Us so that necessary measures can quickly be taken.
7. Third Party Links
These Websites are not intended for use by children under the age of 13.
If you have reason to believe that a child under the age of 16 has provided Personal Information to us through a Website without the appropriate consent, please contact us as provided in the “Contact Us” section below with sufficient detail to enable us to delete that information from our databases.
To fill out a Data Information or Deletion Request, click here.
Do Not Sell My Personal Information: click here.
Do Not Share My Personal Information: click here.
Call us at 1 (612) 317-9420
Email us at [email protected]