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California consumer privacy statement

Effective: 30th June 2020

 

This California Consumer Privacy Statement supplements the Privacy Policy, which describes the personal information that we collect, the sources from which we collect it, the purposes for which we use it, the circumstances under which we share personal information, and with whom we share it. This Statement applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to SPD personnel or job applicants.
This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).


1. Notice of Collection and Use of Personal Information


We may collect the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, pixel tags, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), internet protocol address, email address, account name, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, bank account number, and other financial information and medical information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, sexual orientation, marital and family status, medical condition, pregnancy or childbirth and related medical conditions
  • Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing histories
  • Online Activity: Internet and other electronic network activity information such as information regarding your interaction with websites, applications or advertisements
  • Sensory Information: audio, electronic, visual, and similar information

We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes Categories of Personal Information 
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services •    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance •    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information
 
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

•    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity •    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information
 
Debugging to identify and repair errors that impair existing intended functionality •    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information
 
Undertaking internal research for technological development and demonstration  •    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information
 
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us •    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information
 

 

2. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in Section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.

a. Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection Categories of Personal Information 
Directly from you: 
•    through your use of our site, mobile app or services;
•    through your posts for publication on our website, social media platforms or through our services;
•    contained in or relating to communications that you send to us; or
•    contained in any query you submit to us regarding products and/or services.

•    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information

 

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties Categories of Personal Information
Partners who perform functions on SPD’s behalf

•    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information

Governmental agencies such as law enforcement agencies

•    Identifiers
•    Additional Data Subject to Cal. Civ. Code § 1798.80
•    Protected Classifications
•    Commercial Information
•    Online Activity
•    Sensory Information
 

 

We do not sell personal information and have not sold personal information during the 12-month period prior to the effective date of this Privacy Policy.  


c. Disclosure of Personal Information for a Business Purpose


We may have disclosed to third parties for a business purpose the following categories of personal information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; and Sensory Information.

 

3.    California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.


Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.  
Deletion: You have the right to request that we delete certain personal information we have collected from you. 
Shine the Light Request: If in the future SPD discloses personal information to third parties for direct marketing purposes, you will have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit an access, deletion or a Shine the Light request call us at 1-800-321-3279 or email us at privacy@spdspark.com. SPD will attend to all privacy requests promptly in line with its policy. For CCPA application, you are kindly requested to provide evidence of residence. 

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  We may require you to complete a request form providing any or all of the following information:

  • First and last names;
  • Email address;
  • Telephone number;
  • Full residential address;
  • A copy of certain identification documents; and/or
  • signature.


In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.  We will require you to execute the above referenced declaration and submit it back to us.  If, in our sole determination in accordance with the CCPA, we are unable to verify your identity, SPD may deny the request in whole or in part.


If you designate an authorized agent to make an access or deletion request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).


Please understand that we cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention and legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.


Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This Statement is available in alternative formats upon request.  Please contact privacy@spdspark.com or 1-800-321-3279 (Monday – Friday 8:30 a.m. – 5.00 p.m. Eastern Time, excluding National Holidays, Freephone) to request this Statement in an alternative format.