Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect the following categories of personal information from consumers:
- Category A – Identifiers: Your Name and Email Address.
- Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Your Name and Your Telephone Number.
- Category I – Professional or employment-related information: Your Employer and Company Information.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from You. For example, through information we ask from You when You or Your agents use our Services.
- Directly and indirectly from You when visiting our website. For example, usage details collected automatically in the course of Your interaction with our platform or website or provided by You through a website intake portal.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, to enjoy services offered by our organization.
- To provide You with email alerts and other notices concerning our Services, or updates to the Services.
- To improve our Services to You.
- To market our Services to You.
- For testing, research, analysis and product/service development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing You notice.
Sharing Personal Information
We will not disclose Your personal information to a third party for a business purpose.
We will not sell Your personal information to a third party.
Your Rights and Choices – California Residents
The CCPA provides California residents with specific rights regarding their personal information. This section describes for residents of California those CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to You about our collection and use of Your personal information over the past 12 months. Once we receive and confirm Your verifiable consumer request, we will disclose to You:
- The categories of personal information we collected about You.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about You (also called a data portability request).
Deletion Request Rights
You have the right to request that we delete any of Your personal information we collected from You and retained, subject to certain exceptions. Once we receive and confirm Your verifiable consumer request, we will delete (and direct our service providers to delete) Your personal information from our records, unless an exception applies.
We may deny Your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or perform a contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products 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 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.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us.
Only You or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable consumer request related to Your personal information. You may also make a verifiable consumer request on behalf of Your minor child.
You may only make a verifiable consumer request for access 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.
- Describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to 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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform You of the reason and extension period in writing. We will deliver our written response by mail or electronically, at Your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide Your personal information that is reasonably useable and should allow You to transmit the information from one entity to another entity without hindrance.
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.
We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny You use of our Services.
- Provide You a different level or quality of Services.
Changes to Our Privacy Notice
Updated December 1, 2020