|A.||Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B.||Personal information categories are listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card 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.||YES|
|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).||YES|
|D.||Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E.||Biometric information.||Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F.||Internet or other similar network activity.||Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement.||NO|
|G.||Geolocation data.||Physical location or movements.||NO|
|H.||Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I.||Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J.||Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student are maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K.||Inferences are drawn from other personal information.||The profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information is covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our customers or their agents. For example, from information submitted to us via our website.
- Indirectly from our customers or their agents. For example, through information, we collect from our customers in the course of providing services to them
- Directly and indirectly from activity on our website. For example, submissions through our website portal or website usage details are collected automatically.
Use of Personal Information We may use or disclose the personal information we collect for one or more of the following business purposes:
- To provide you with information, products, or services that you request from us.
- To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis, and product development.
- As necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Sharing Personal Information We may disclose your personal information to a third party for business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Category A: Identifiers. Category B: California Customer Records personal information categories. Category C: Protected classification characteristics under California or federal law. Category E: Internet or other similar network activity. We disclose your personal information for a business purpose to the following categories of third parties:
- Our business affiliates.
- Third-party service providers
- Other third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide 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, 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
- 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, 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 his or her free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
- 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.
Rights to Opt-Out of Sale of Your Personal Information California privacy laws require us to provide California residents with the option to opt-out of current or future sales of their information. This information includes, but is not limited to name, postal or email address, and other personally-identifying information. You need not be physically present in California to exercise this right so long as you have a current California residence. This right is subject to certain exemptions. For example, the law does not apply to information that has been aggregated and/or de-identified such that it could not reasonably be used to identify you. It also does not apply to information that we share with third-party service providers in order for them to perform certain business functions for us. Exercising Access, Data Portability, Deletion, and Opt-Out Rights If you would like to exercise any of your rights provided by the CCPA, such as the right to access or delete your personal information, or to opt-out of the sale or future sale of your personal information you or your authorized agent or representative may contact us in writing via email at email@example.com or physically at 100 E Sample Rd., Suite 320, Pompano Beach, FL 33064. As with the right to opt-out, the other rights provided by the CCPA are subject to certain exemptions and exceptions, as specified in the applicable federal statutes and/or associated regulations issued by California’s Office of the Attorney General. Those statutes and/or regulations may also stipulate the maximum time allowed for acknowledging and responding to a request. There is no charge for making privacy-related requests. Verifying a Request Please note that only you or a person registered with the California Secretary of State that you authorize 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. In order to better safeguard your privacy and the privacy of others, we may be required to verify your identity before processing certain data-related requests. 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.
- 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. Additionally, in some cases, we may be unable to fulfill your request because we have no way to verify your identity to the standard the law and/or its associated regulations require. For example (but without limitation), if you have visited our website, but never left a comment, submitted a Contact Form, completed a financial transaction with us, or interacted with us via email or other means, we probably do not have enough information to confirm your identity to even a “reasonable degree of certainty” (as the applicable regulations may define that term). Please note that 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. Please be aware that, in addition to any other exemptions applicable law and/or regulation may provide to your rights under the CCPA, specifically with regard to the deletion of your personal information, we may be unable to delete certain information due to regulatory requirements or other technical reasons (e.g., our web host’s server and error logs). 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 will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 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 useable 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. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.