Last updated: 2019-12-24 4:05:47 PM
We understand that privacy online is important to users of our Site, especially when conducting business. This statement governs our privacy policies with respect to those users of the Site who visit without transacting business (“Visitors”) and users who register to transact business on the Site and make use of the our services (collectively, “Services”) (“Authorized Customers”).
“Personally Identifiable Information”
Refers to any information that identifies or can reasonably be used to identify, contact, or locate the person to whom such information pertains, including, but not limited to, name, address, phone number, fax number, email address, financial profiles, social security number, and credit card information. Personally Identifiable Information does not include information that is collected anonymously (that is, without identification of the individual user) or demographic information not connected to an identified individual.
What Personally Identifiable Information is collected?
We may collect basic user profile (i.e – browsing history, IP address, etc.) information from all of our Visitors. We collect the following additional information from our Authorized Customers: the names, addresses, phone numbers and email addresses of Authorized Customers, the nature and size of the business, and the nature and size of the advertising inventory that the Authorized Customer intends to purchase or sell.
What organizations are collecting the information?
In addition to our direct collection of information, we may use third party service vendors (such as clearinghouses and banks) to provide services on our behalf (such as insurance) and escrow services may collect this information from our Visitors and Authorized Customers. We provide information to these third-party providers for the limited purpose of fulfilling orders, rendering payment and performing the services on our behalf. We do ask them to disclose how they use personal information provided to them from Visitors and Authorized Customers. Some of these third parties may be intermediaries that act solely as links in the distribution chain, and do not store, retain, or use the information given to them, but we do not control how these parties ultimately use, store or delete the information.
How does the Site use Personally Identifiable Information?
We use Personally Identifiable Information to customize the Site, to make appropriate service offerings, and to fulfill buying and selling requests on the Site. We may email Visitors and Authorized Customers about research or purchase and selling opportunities on the Site or information related to the subject matter of the Site. We may also use Personally Identifiable Information to contact Visitors and Authorized Customers in response to specific inquiries, or to provide requested information.
With whom may the information may be shared?
Personally Identifiable Information about Authorized Customers may be shared with other Authorized Customers who wish to evaluate potential transactions with other Authorized Customers. We may share aggregated information about our Visitors, including the demographics of our Visitors and Authorized Customers, with our affiliated agencies and third party vendors. We also offer the opportunity to “opt out” of receiving information or being contacted by us or by any agency acting on our behalf.
California Residents Rights
California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
Do-Not-Sell. California residents have the right to opt-out of our sale of their personal information. Opt-out rights can be exercised on our Do-Not-Sell page. We do not sell personal information about residents who we know are younger than 16 years old.
Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
Categories of Personal Information that We Collect, Disclose, and Sell
Below please find the categories of personal information about California residents that we collect, sell, and/or disclose to third parties or service providers for a business purpose.
| Categories of personal information (Last Updated: Dec 13 2019) |
Do we collect? | Do we disclose for business purpose? | Do we sell? |
|---|---|---|---|
| NAME, CONTACT INFORMATION AND IDENTIFIERS: Identifiers such as 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 | NO | NO |
| CUSTOMER RECORDS: Paper and electronic customer records containing personal information, such as name, signature, social security number, Signature, 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. | NO | NO | NO |
| PROTECTED CLASSIFICATIONS: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information. | NO | NO | NO |
| PURCHASE HISTORY AND TENDENCIES: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO | NO | NO |
| BIOMETRIC INFORMATION: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | NO | NO | NO |
| USAGE DATA: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement. | YES | NO | NO |
| GEOLOCATION DATA: recise geographic location information about a particular individual or device | NO | NO | NO |
| AUDIO/VISUAL: Audio, electronic, visual, thermal, olfactory, or similar information. | NO | NO | NO |
| EMPLOYMENT HISTORY: Professional or employment-related information. | NO | NO | NO |
| EDUCATION INFORMATION: Information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). | NO | NO | NO |
| PROFILES AND INFERENCES: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO | NO | NO |
Verifiable Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months. Please see our CCPA Request page to submit a request directly to Kylli.
Right of Deletion: The right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary that we maintain such personal information in order to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- 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 businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
- Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
- Comply with a legal obligation.
- Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Right to a Copy: The right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.
Right to Know: The right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting and selling their personal information;
- categories of third parties/with whom we have disclosed or shared their personal information;
- categories of personal information that we have disclosed or shared with a third party for a business purpose;
- categories of personal information collected; and
- categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.
How is Personally Identifiable Information stored?
Personally Identifiable Information collected on this site is securely stored and is not accessible to third parties or our employees except for use as indicated above.
What choices are available to Visitors regarding collection, use and distribution of the information?
Visitors and Authorized Customers may opt out of receiving unsolicited information from or being contacted by us and/or our vendors and affiliated agencies by responding to emails as instructed, or by contacting us.
Submitting Requests. Requests to exercise the right to deletion, right to a copy, and/or the right to know may be submitted on our CCPA Request page, by contacting us at +1 (650) 373-2073 (toll free), or by emailing us at [email protected]. We will respond to verifiable requests received from California consumers as required by law.
Are Cookies Used on the Site?
Cookies are used for a variety of reasons. We use Cookies to obtain information about the preferences of our Visitors and the services they select. We also use Cookies for security purposes to protect our Authorized Customers. For example, if an Authorized Customer is logged on and the site is unused for more than 10 minutes, we will automatically log the Authorized Customer off.
We use “cookies,” web beacons, and other technologies to collect automatically the following information and similar information about your use of our Site or Services: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and/or use our Services; and the referring URL, or the web page that led you to our Site. We do not respond to web-browser “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Site. As discussed below, you may opt out of tracking by third-party network advertisers.
Third-Party Analytics. We use third-party service providers, including Google Analytics, to evaluate and analyze the activities of visitors to our Site, including the use of our Services. We use analytics to help us improve our Site and our Services, performance, and user experiences. These third-party service providers will use cookies and other tracking technologies to conduct the analytics.
How does the Site keep Personally Identifiable Information secure?
All of our employees are familiar with our security policy and practices. The Personally Identifiable Information of our Visitors and Authorized Customers is only accessible to a limited number of qualified employees who are given a password in order to gain access to the information. We audit our security systems and processes on a regular basis. Sensitive information, such as credit card numbers or social security numbers, is protected by encryption protocols, in place to protect information sent over the Internet. While we take commercially reasonable measures to maintain a secure site, electronic communications and databases are subject to errors, tampering and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to Visitors or Authorized Customers for any such occurrences.
What happens if the Privacy Policy Changes?
We will let our Visitors and Authorized Customers know about changes to our privacy policy by posting such changes on the Site. However, if we are changing our privacy policy in a manner that might cause disclosure of Personally Identifiable Information that a Visitor or Authorized Customer has previously requested not be disclosed, we will contact such Visitor or Authorized Customer to allow such Visitor or Authorized Customer to prevent such disclosure.
Links
This site contains links to other websites. Please note that when you click on one of these links, you are moving to another website. We encourage you to read the privacy statements of these linked sites as their privacy policies may differ from ours.