PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Trusted Media Brands, Inc. and its U.S. subsidiaries and/or affiliates under its control (collectively, “we,” “us,” or “our”) with respect to the Service (as defined in such Privacy Policy) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We provide this notice under: (1) the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 et seq., as amended or supplemented from time to time (“CCPA”), and (2) California’s “Shine the Light” law, Cal. Civ. Code § 1798.83. Any terms defined in the CCPA have the same meaning when used in this notice.
This notice and our initial CCPA compliance program reflect our good faith effort to interpret the law and are subject to revisions as regulatory guidance and industry consensus develops.
Our Personal Information Practices
The following is a description of our personal information practices for the 12-month period prior
to the date of update of this notice set forth above. See our applicable privacy policies and
notices at the point of collection for more current information on our practices.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve 12 months from the sources and for the uses as described below:
Category | Brief Description |
---|---|
A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
B. Personal Records | A name, signature, physical characteristics or description, address, telephone 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. |
E. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
F. Geolocation data | Physical location or movements. |
G. Inferences drawn from above personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose as set forth in the CCPA, including as follows (parenthetical references are to subsections of CCPA § 1798.140(d)):
Auditing (1)
Categories A, B, E, F & G
Short-term, transient use (4)
Categories A, B, E, F & G
Performing services (5)
Categories A – G
Research for technological development (6)
Categories A, B, E, F & G
To verify or maintain quality or safety (7)
Categories A, B, E, F & G
When we disclose personal information for a business purpose, we enter into a contract for that purpose requiring the recipient to keep that personal information confidential and only use it as necessary to perform the business purpose, or as otherwise permitted by applicable law.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A:
Identifiers
Category B:
Personal Records
Category C:
Protected classification characteristics under California or federal
law
Category D:
Commercial Information
Category E:
Internet or other similar network activity
Category F:
Geolocation data
Category G:
Inferences drawn from above personal information
We disclose your personal information for a business purpose to the following categories of third parties:
We may sell personal information we collect about you to third parties. In the preceding twelve (12) months, we have sold the following categories of personal information.
Category A:
Identifiers
Category B:
Personal Records
Category C:
Protected classification characteristics under California or federal
law
Category D:
Commercial Information
Category E:
Internet or other similar network activity
Category F:
Geolocation data
Category G:
Inferences drawn from above personal information
There is not currently a consensus as to whether or not collection of your data and disclosure of it to third parties by cookies and other tracking technologies should be deemed a sell of your personal information by us under the CCPA. However, we use one or more types of technology to signal to cookie operators when a device you use has registered a do not sell request with us, and we may offer you other ways to control cookies associated with our services. We are not responsible for the effectiveness of these tools or the manner in which third parties treat your choices or our signals. For more information on cookies and your choices regarding them, including how to opt-out of certain interest-based advertising, see our Privacy Policy.
We do not knowingly sell without affirmative authorization the personal information of persons who we are aware are minors under 16 years of age.
Your Rights and Choices
The CCPA provides California consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Do Not Sell
You have the right to opt out of the sale of your personal information. Once we receive and confirm your verifiable consumer request, we will refrain from selling personal information we collected about you; provided, however with respect to cookies your do not sell request to us will result in our use of one or more types of technology to signal to cookie operators when a device you used at the time of opt-out has registered a do not sell request with us, and we may offer you other ways to control cookies associated with our services. We are not responsible for the effectiveness of these tools or the manner in which third parties treat your choices or our signals. For more information on cookies and your choices regarding them, including how to opt-out of certain interest-based advertising, see our Privacy Policy.
Access to Specific Information
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 as you requested:
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, 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:
Exercising Do Not Sell, Access and Deletion Rights
To exercise the do not sell, access and deletion rights described above, please submit a verifiable consumer request to us as follows:
Do Not Sell
Access Requests
Deletion Requests
Follow the instructions that you will be provided to help us verify you and respond to your requests.
Only you or an authorized agent verified 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 twice within a 12-month period. The verifiable consumer request must:
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. If you have an account with us, we may deliver our written response to that account, or by mail or electronically. If you do not have an account with us, we will deliver our written response by mail or electronically. Any disclosures we provide need 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 provide your personal information in a standard CSV file.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded, in which case we may limit the response and/or condition it on payment of our costs. 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. Unless permitted by the CCPA, we will not:
Changes to this Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will update the date of this notice below. Please bookmark this page and check it periodically. We will post any changes online.
Contact Information
If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us through the means set forth above for Do Not Sell requests under “Exercising Do Not Sell, Access and Deletion Rights”.
“Shine the Light” Law
California’s “Shine the Light” law, Cal. Civ. Code § 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. If you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes, you may do so by submitting a Do Not Sell request through the means set forth above under “Exercising Do Not Sell, Access and Deletion Rights” or as set forth in our Privacy Policy under “Notice of Your Choices about Our Use and Sharing of Personally Identifiable Information”. To find out more about your opt-out rights and how we comply with this law, please contact us as set forth in that section above for Do Not Sell requests or as set forth in the section of our Privacy Policy referenced above.
Any California residents under the age of eighteen (18) who have registered to use our service, and who posted content or information on our service, can request removal by contacting us as described above. We will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.