Information for California Residents

Effective Date: December 12, 2019

This section applies only to California residents and describes how we collect, use and share their Personal Information in operating our business, and their rights with respect to that Personal Information.  “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted or otherwise excluded from the scope of the CCPA. 

Your California privacy rights.

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. 

  • Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of recipient.
    • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of recipient.
  • Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Deletion.  You can ask us to delete the Personal Information that we have collected from you.
  • Opt out of sales.  If we sell your Personal Information, you can direct us to stop. 
  • Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.  

How to exercise your rights

You may exercise your California privacy rights described above as follows:

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Personal information that we collect, use and share

The chart below summarizes the categories of Personal Information that we collected, used and shared during the 12 months before the effective date of this Privacy Policy.

Category (click to link to glossary definition) Do we collect this information? Do we share this information for business purposes? Do we “sell” this information?
Identifiers Yes Yes No
Online Identifiers Yes Yes No
Protected Classification Characteristics Yes, but only if you volunteer it to us Yes No
Commercial Information Yes Yes No
Biometric Information  No No No
Internet or Network Information Yes Yes No
Geolocation Data No No No
Sensory Information No No No
Professional or Employment Information No No No
Education Information No No No
Inferences Yes Yes No
Financial Information No No No
Medical Information No No No
Physical Description No No No

We describe: 


We do not “sell” your Personal Information as defined under the CCPA for analytics, marketing and advertising purposes.  

Glossary
Category Definition/Description (categories may overlap)
Biometric Information  An individual’s physiological, biological or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Education Information Personal information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
Financial Information Bank account number, debit or credit card numbers, insurance policy number, and other financial information.
Geolocation Data For example, your precise location derived from GPS coordinates or telemetry data.
Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. 
Inferences The derivation of information, data, assumptions, or conclusions from any of the above categories of Personal Information to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Internet or Network Information Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement.
Medical Information Personal information about an individual’s health or healthcare, including health insurance information.  Does not include (a) medical information governed by California’s Confidentiality of Medical Information Act, (b) protected health information that is collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 or (c) information collected as part of certain clinical trials.
Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.
Physical Description An individual’s physical characteristics or description.
Professional or Employment Information This term is not defined in the CCPA, but likely includes any information relating to a person’s current, past or prospective employment or professional experience (e.g., job history, performance evaluations).
Protected Classification Characteristics 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).
Sensory Information Audio, electronic, visual, thermal, olfactory, or similar information.