Last Updated: March 13, 2020
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing this California Consumer Privacy Act Notice (“CCPA Notice”). This CCPA Notice supplements our Privacy Policy and applies solely to California consumers, effective January 1, 2020. Terms used but not defined shall have the meaning ascribed to them in the CCPA.
The chart below outlines the categories of Personal Information (which are defined by the CCPA, not us) that we have collected and/or disclosed for a business purpose in the preceding twelve months. The examples of Personal Information provided for each category are taken from the CCPA and are included to help you understand what the categories mean. The examples are not meant to indicate what we actually collect or disclose, and more information about our specific practices can be found in our Privacy Policy.
We collect the following categories of personal information as indicated with a check mark below
| A. Identifiers such as a real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name. | |
| B. Personal information as defined in the California customer records law, such as name, contact information, education, employment, employment history and financial information. | |
| C. Characteristics of protected classifications under California or federal law. | |
| D. Commercial information, such as transaction information, purchase history, financial details and payment information. | |
| E. Biometric information, such as fingerprints and voiceprints. | |
| F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements. | |
| G. Geolocation data, such as device location. | |
| H. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities. | |
| I. Professional or employment-related information, such as job title as well as work history and experience in presenter bios collected for events, presentations, marketing collateral and testimonials in connection with our business activities. | |
| J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records. | |
| K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics. |
We collect this personal information from you and from other categories of sources such as: our affiliates; our customers; public and publicly available sources; our third-party resellers and referral partners, vendors, data suppliers and service providers; and partners with which we offer co-branded services or engage in joint event or marketing activities.
We share this personal information with: our affiliates; our customers; our vendors, service providers, suppliers, agents and representatives; joint venture partners; other entities offering products and services that may be of interest to you; resellers, distributors, referral partners and integrators; licensors of third-party applications (if you access a third-party application on our services through a license agreement with the licensor); and other parties where required by law or to protect our rights.
We may use this personal information to operate, manage, and maintain our business, to provide our products and services, to communicate with you, for our vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using personal information to: develop, improve, repair, and maintain our products and services; process or fulfill a request or other transactions submitted to us; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions; comply with law, legal process, and internal policies; maintain records; exercise and defend legal claims; and fulfill legal obligations.
We disclose the following categories of personal information as indicated with a check mark below to our affiliates; our customers; our vendors, service providers, suppliers, agents and representatives; joint venture partners; other entities offering products and services that may be of interest to you; resellers, distributors, referral partners and integrators; licensors of third-party applications (if you access a third-party application on our services through a license agreement with the licensor); and other parties where required by law or to protect our rights for our operational business purposes:
| A. Identifiers such as a real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name. | |
| B. Personal information as defined in the California customer records law, such as name, contact information, education, employment, employment history and financial information. | |
| C. Characteristics of protected classifications under California or federal law. | |
| D. Commercial information, such as transaction information, purchase history, financial details and payment information. | |
| E. Biometric information, such as fingerprints and voiceprints. | |
| F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements. | |
| G. Geolocation data, such as device location. | |
| H. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities. | |
| I. Professional or employment-related information, such as job title as well as work history and experience in presenter bios collected for events, presentations, marketing collateral and testimonials in connection with our business activities. | |
| J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records. | |
| K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics. |
You have the right to request that we disclose to you (i) the categories of personal information we collected about you and the categories of sources from which we collected such information; (ii) the specific pieces of personal information we collected about you; (iii) the business or commercial purpose for collecting personal information about you; and (iv) the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months. You also have the right to request that we delete personal information we collected from you subject to certain exceptions.
You also have the right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA. We do not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.
You may make a request for the disclosures or deletion described above through the "Do Not Sell My Personal Information" / CCPA Request Form.
You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.
We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and certain other laws, and where its application is preempted by, or in conflict with, federal law or the United States or California Constitution.
We will update this CCPA Notice from time to time. Any changes will be posted on this page with an updated revision date.