8. Notice to California Residents
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” as defined in the California Consumer Privacy Act (“CCPA”), as well as information about your rights under the CCPA.
We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities with which we share such information in the “Information We Collect”, “Use of Information,” and “Sharing of Information” sections of this Privacy Policy. We provide additional information required by the CCPA below. This information and the rights discussed below (except in some cases the right of California consumers to opt out of “sales” of their personal information) do not apply to information collected from or about our employees, former employees, candidates, job applicants, contractors, service providers, or our business contacts.
A. Categories of personal information we collect, use and disclose.
Throughout this Privacy Policy, we discuss in detail the types of Information we collect from and about users and discuss how we use and share such information. The following are the “categories” of personal information under the CCPA that we collect from California consumers and that we may, as discussed throughout this Privacy Policy, use and disclose for our business purposes:
Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history or app usage); general geolocation data from IP addresses; characteristics of potentially protected classifications, such as gender, race/color and marital status; any user-generated content or feedback that you provide; professional or employment related data; inferences drawn from the information we collect about you that may reflect your preferences or interests; and other information that identifies or can be reasonably associated with you.
B. How we use these categories of personal information
We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law).
- Our or our service providers’ operational purposes;
- Auditing consumer interactions on or off our Services (e.g., measuring ad impressions);
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
- Bug detection and error reporting;
- Customizing content that we or our service providers display on or off the Services (e.g., personalized ands or content);
- Providing the Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services);
- Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
- Verifying or maintaining the quality or safety of our Services, and to improve, upgrade, or enhance our Services.
- Other uses that advance our commercial or economic interests, such as third-party advertising;
- Other uses about which we notify you.
Examples of these types of uses are discussed in our main privacy policy in the “Use of Information” section. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any user or device.
C. Categories of personal information we disclose for a business purpose
We may disclose the following categories of information about you or your use of our Services for business purposes (as defined by applicable law) or as required by applicable law:
Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history or app usage; general geolocation data from IP addresses; characteristics of potentially protected classifications, such as gender, race/color, and marital status; any user-generated content or feedback that you provide; professional or employment related data; inferences drawn from the information we collect about you that may reflect your preferences or interests; and other information that identifies or can be reasonably associated with you.
D. Sale of personal information
California residents have the right to opt out of the sale of their personal information under the CCPA.
As explained further in this Privacy Policy, we and our advertising partners collect and share certain pieces of information about the use of our Services such as device identifiers, cookies, device IDs, IP addresses, and usage activity, so that we and third parties can deliver ads that are more relevant to you. This type of information sharing with our advertising partners may be considered a “sale” under the CCPA. To learn how opt out of this type of “sale” by participating companies, you can visit the CCPA Opt Out Tool provided by the Digital Advertising Alliance at https://www.privacyrights.info/.
The opt outs described above are device- and browser-based. Because the information being shared relates to your device ID and/or browser ID, you must opt out on each device and each browser where you want your choice to apply. Opt-outs may be stored via cookies. If you clear cookies in your browser, your opt-out preference may also be cleared, in which case you would need to opt out again on that browser if you want your choices to apply. VergeSense does not maintain or control the opt-out mechanisms and settings above and is not responsible for their operation.
E. Access
You have the right to request certain information about our collection and use of your personal information over the past 12 months, including:
- The categories of personal information that we have collected about you.
- The categories of sources from which that personal information was collected.
- The business or commercial purpose for collecting or selling your personal information.
- The categories of third parties with whom we have shared your personal information.
- The specific pieces of personal information that we have collected about you.
F. Deletion
You have the right to request that we delete the personal information that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your personal information to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
G. Exercising Your Access and Deletion Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use personal information provided in a Valid Request to verify your identity and respond to your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
There are various exceptions to your rights to Access and Deletion under the CCPA, and in some cases we are not required by the CCPA to complete your request in connection with personal information we obtain about you when you are acting as an employee, owner, director, officer, or contractor of a business, even if it is otherwise a Valid Request. If we do not respond to your request fully, we will provide you additional information about the reasons why.
H. Authorized Agents
You may designate an agent to make the requests described above. If you do so, we will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized by you to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
I. We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of personal information that we receive from you.
J.California Resident “Shine the Light” Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of personal information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@vergesense.com.
