ADDENDUM FOR CALIFORNIA RESIDENTS
CALIFORNIA PRIVACY RIGHTS
Last Modified: Nov 5, 2021
NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA
CONSUMER PRIVACY PROTECTION ACT
In the below tables and sections, we describe (as required by the CCPA):
- Our Collection of Personal Information– the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,
- Our Disclosure and Sale of Personal Information– the types of recipients to whom we disclose or sell Personal Information.
- Our Business Purposes– our business purposes for (a) collecting and (b) sharing Personal Information,which are generally the same.
- Your California Privacy Rights and Choices– what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.
The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:
1. OUR COLLECTION OF PERSONAL INFORMATION
Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
Categories of Sources
E.g., IP address; mobile ad identifiers; hashed email address.
Data compilers, mobile applications, advertising networks and platforms.
Geo location data
Mobile applications, data compilers;
Professional or employment-related information
E.g., current or past job history or performance evaluations.
2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION
We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below describes how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.
Categories of Third Parties We Share With
Whether We “Sold” This Category of Personal Information in the Last 12 Months
Identifiers, e.g., mobile ad identifiers; other device or online identifiers; IP address; hashed email address;
Advertising networks (e.g., demand-side platforms, agency trading platforms), agencies and advertisers, data compilers and resellers, data analytics providers, marketing research providers, financial institutions, government entities, and information services and publishers (“Customer Categories”).
see “Customer Categories” above
E.g., inferences based on a device’s location or traffic history.
see “Customer Categories” above
We also may share any of the personal information we collect as follows:
We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Sharing With Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.
Sharing of Aggregate Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION
Our Purposes for collecting, using and sharing Personal Information
Online targeting, for example:
- Assisting advertisers, agencies and the platforms that they access (a) to deliver advertising and marketing to send, tailor, optimize and analyze advertising, in mobile apps and across other advertising channels and platforms and (b) to measure and analyze such advertising and marketing.
- Create “audience segments” based on inferences about consumer preferences, products and activities for purposes of online and mobile advertising.
- Assisting Clients by creating “identity” graphs, to help locate users across various channels, such as connecting identities based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).
Online targeting, for example:
Providing information for research purposes related to human traffic patterns, including for purposes of market, public health, financial, or consumer research.
Operating our Services, for example:
- Improving, testing, updating and verifying our own data and data services.
- Developing new products.
- Operating, analyzing, improving, and securing our Services.
Online targeting, for example:
For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We use the information collected from our own website, from social networks, from other “business to business” interaction (such as at trade shows) or from data compilers for the above, as well as for our own marketing purposes.
4. YOUR CALIFORNIA RIGHTS AND CHOICES
Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, to the extent as act as a “business” (as opposed to a “service provider”) for purposes of handling personal information. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)
a. Right to Opt-out of the sale of your personal information.
b. Right to request deletion of your personal information
You may also request that we delete any personal information that we collected from you, such as if you have been a customer of ours. To make such a request, please send an email to [email protected] (Note that this is different from your right to “opt out” of us selling your personal information, which is described below; also note that we do not generally collect personal information directly from consumers, in which case “deletion” rights generally do not apply.)
However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
c. Right to request access to your personal information
California residents also have the right to request that we disclose what categories of your personal information we collect, use, or sell. As a California resident, you may request access to the specific pieces of personal information that we have collected from you.
California residents may learn more how to exercise these rights of information access by sending an email to [email protected], submitting a request to Request Information, or by contacting us at (855) 856-3404.
We will then request certain information about you, including your device identifier (and we may request a screen shot of that identifier).
California residents likewise have a right to request and in some cases to receive access to the specific pieces of personal information that has been collected about them, upon making a verifiable request. We are not able to provide such specific pieces of personal information, beyond basic device information and identifiers, because we are not able to verify to a reasonably high degree that the personal information we have pertains to the person who has submitted the request, or whether either the person in possession of a device or the person requesting the information is the actual device owner. (Studies have concluded that many people do not, or do not sufficiently, password-protect their mobile devices.)
Moreover, because we do not collect information such as name, address or email address (which we avoid, to protect consumer privacy), we do not have other, more conventional ways to verify the identify of an actual device owner.
If you are uncomfortable with your device information being used in the ways described above, we recommend that you request an “opt out” your information as described above.
We will, however, provide categories and certain device information once we have verified your identity, and at that time we will respond to your request as appropriate:
d. How to exercise your access, opt-out and (if applicable) deletion rights
For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.
Once we have verified your identity, we will respond to your request as appropriate:
- Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
- Where you have requested that we delete personal information that we have collected from you, we will seek to confirm whether your request is for an “opt out” or a “deletion”: because “opt out” or “do not sell” rights enable us to maintain your information for “suppression” purposes – i.e., to prevent us from selling information about you in the future (which is what many consumers requesting “deletion” actually desire to occur), we try to explain this in order to ensure we are meeting consumers’ preferences. (In addition, “deletion” rights only apply to information that we have collected “from” consumers – which does not apply to much of the information in our databases.)
- Upon completion of the above process, we will send you a notice that explains the categories of personal information we were able to locate about you, whether we (1) deleted, (2) de identified, or (3) retained the information we collected from you. Certain information may be exempt from such requests under applicable law.
If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.
e. Right to nondiscrimination.
We do not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
f. Information About Persons Under 16 Years of Age
We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).
g. Authorized Agents
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.