|
Category Collected | Exemplar | Source | Business Purpose | Share or Sale |
Identifiers | First and Last Name, Postal Address, Unique Personal Identifier, Online Identifier, Internet Protocol Address, Email Address | Directly and indirectly from consumers, Third party data providers, Ad exchanges, Supply-side platforms, Clients | Personalize Website; Respond to Consumer request; targeted advertising through Google. Provide services or products requested by consumer; Process consumer and client invoicing and payments; Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. | Service providers, Contractors, Third-party vendors and data management companies; ESP providers, Clients, Affiliated companies |
Personal and Sensitive Information | First and Last Name, Address, Telephone Number, Credit Card or Debit Card when purchases are made | Directly from Consumers | To process consumer requests for purchases, transactions, Payments, or Prevent fraud | Service providers, Contractors Third-party vendors, Clients, Affiliated companies |
Commercial Information | Records of products or services purchased, obtained, or considered. History or tendencies toward products and services or response to advertising. | Directly and indirectly from consumers, Third party data providers, Technology providers and Ad exchanges, Supply-side platforms, Clients | Personalize Website; Respond to Consumer request; targeted advertising through Google AdWords. Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. To process consumer requests, purchases, transactions, payments, and prevent fraud. | Service providers, Contractors, Third-party vendors, Clients, Affiliated companies |
Internet or other Similar Network Activity | Browsing history, Search history, Information on a consumer's interaction with a website, application, or advertisement | Directly and indirectly from consumers, third party data providers, Ad exchanges, Tech and analytics third party platforms, Clients | Personalize Website; Respond to Consumer request; targeted advertising through Google. Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, marketing and services. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. | Service providers, Contractors, Third-party vendors, Clients, Affiliated companies |
Geolocation Data | Through collection of your IP, we collect your general location, upon requesting services, or product we collect your physical address | Directly and indirectly from consumers, Third party data providers, Tech and analytics third party platforms, Clients. | Personalize Website; Respond to Consumer request; targeted advertising through Google. Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. | Service providers, Contractors, Third-party vendors, Clients, Affiliated companies |
Inferences Drawn from other Personal Information | From information we collect as set forth herein and information provided by third-parties, we are able to profile a general understanding of your preferences, characteristics, and personal preferences to determine what ads or products or services you may be interested in receiving. | Directly and indirectly from consumers, Third party data providers, Third party analyst companies, Tech and analytics third party platforms, Clients | Personalize Website; Respond to Consumer request; targeted advertising through Google. Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services. | Service providers, Contractors, Third-party vendors, Clients, Affiliated companies |
Highly Sensitive Information | Credit card or financial information for purposes of a transaction involving our products or services. | Consumers | To respond to request of consumer for products or services | Marchant account provider Porcessor Clients |
Your Rights and Choices.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to and Correction of Specific Information and Data Portability Rights.You have the right to request that we disclose and or correct 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 (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you:
- 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 or selling 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).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights.
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. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), 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 provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 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.
- 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.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Right to Opt-Out of the Sale of Personal Information.
You have the right to opt-out of any sale of your Personal Information by us. If you are requesting a product or service, this is an exemption from this right, and we will process your request. However, you have the right to cease all further sale of your Personal Information. You may email us or use our web portal and fully fill out the request form.
Opt-Out Preference Signal (Global Privacy Control).
You may use an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”), to opt-out of the sale/sharing of your personal information. However, this technology and our use of it is not fully developed by the market. Our database containing your information may not be linked to your browser identification and because your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account or database information as the connection between your browser and our database is not known to us, we may not be able to fulfill this request.
If you would like us to make the connection between your browser and your account within our database, please email us or submit the requested form through our website portal below.
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 either:
- Visiting and calling the Toll Free Number listed on our web portal : optconsumerprivacy.com
- Visiting and completing the form on our web portal: optconsumerprivacy.com
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. The appointment must be in writing and presented by your agent. If your authorized agent requests sensitive information about you then we may ask you to provide us with a sworn declaration to further verify your identity.
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, which may include:
- You will be required to provide your full name, email address, and zip code.
- 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 will honor your request to cease sharing and sale within ten (10) days of receipt of your request and endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by email unless you request, we mail the same to you and provide a current mailing address.
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 readily usable 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.
Non-Discrimination.
We will not discriminate against you for exercising any of your CCPA rights.
Retention of Personal Information.
We retain Personal Information as long as is reasonably necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation or contractual provision. We will retain your Personal Information for the purposes of commercial marketing to you until you request we cease further efforts to provide you such offers or in the event you request deletion of your Personal Information. To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.
Changes to Our Privacy Notice.
We reserve the right to amend this privacy notice at our discretion and at any time. The only notice to you will be our posting of the updated notice on the Website and update the notice's effective date.